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“dispute resolution panel”

Assessment ProceduresSection 144CSection 144C2,746 judgments

The decision most relied on for dispute resolution panel is Commissioner of Income Tax v. Roca Bathroom Products (P) ltd. (445 ITR 537), cited in 269 judgments on BharatTax.

Leading authorities on dispute resolution panel

Commissioner of Income Tax v. Roca Bathroom Products (P) ltd.
445 ITR 537 · 2022 · High Court
269
citing judgments

The time limit for the Assessing Officer to pass a final assessment order under Section 144C(13) following directions from the Dispute Resolution Panel is determined by the specific provisions of Section 153, particularly Section 153(2A).

Shelf Drilling 4. In ACIT (International Taxation) v. Shelf Drilling Ron Tappmeyer Ltd.
177 Taxmann.com 262 · 2025 · Supreme Court
216
citing judgments

The Supreme Court has not reached a majority verdict on whether the time spent in Dispute Resolution Panel (DRP) proceedings under Section 144C should be included within the overall limitation period prescribed by Section 153(3). Consequently, the legal position on the interplay between Sections 144C and 153 remains unresolved at the Supreme Court level.

Shelf Drilling Ron Tappmeyer Ltd. v. ACIT\n(Intl. Taxation)
153 Taxmann.com 162 · 2023 · High Court
169
citing judgments

The time consumed in proceedings before the Dispute Resolution Panel (DRP) under Section 144C must be subsumed within the limitation period prescribed under Section 153 for the completion of assessment, meaning these timelines are not mutually exclusive.

ESPN Star Sports Mauritius S.N.C. ET Compagnie v. Union of India
388 ITR 383 · 2016 · High Court
71
citing judgments

Failure to issue a draft assessment order under Section 144C(1) makes the final assessment order illegal and beyond jurisdiction. Non-compliance with Dispute Resolution Panel (DRP) directions renders the final assessment order bad in law.

Roca Bathroom Products (P.) Ltd. v. Dispute Resolution Panel-2
127 Taxmann.com 332 · 2021 · High Court
57
citing judgments

A High Court decision is binding on subordinate authorities like the Assessing Officer. The Assessing Officer erred in not following a prior jurisdictional High Court ruling and a Madras High Court ruling.

Vodafone India Services Pvt. Ltd. v. Addl. CIT & Ors.
361 ITR 531 · 2014 · High Court
40
citing judgments

Proceedings before the Dispute Resolution Panel (DRP) are a continuation of the assessment proceedings, not an appeal. The DRP's role is to act as a correcting mechanism, providing a second review of the proposed assessment order.

CIT v. Tata Power Solar Systems Ltd.
77 Taxmann.com 326 · 2017 · High Court
25
citing judgments

An assessee can withdraw a company from the list of comparables if it was inadvertently included and is not genuinely comparable.

S.A. Builders Ltd. v. CIT(Appeals)
338 ITR 482 · 2011 · High Court
23
citing judgments

The deletion of a disallowance under Section 36(1)(iii) by the Dispute Resolution Panel (DRP) is upheld when relied upon by other judgments.

Judgments citing dispute resolution panel

Jungheinrich Lift Truck India Private Limited, Mumbai vs. Assessment Unit, National E Assessment Centre- Delhi, Delhi

In the result, the appeal is accordingly allowed for statistical purposes

ITA 4260/MUM/2024[2020-2021]Status: DisposedITAT Mumbai21 May 2025AY 2020-2021

Bench: Ms. Padmavathy S & Shri Raj Kumar Chauhanvs. Assessment Jungheinrich Lift Truck Unit/Nfac/Dcit India Private Limited Circle 15(1)(2), 4Th Floor, Delphi A Wing, Mumbai Central Avenue, Aayakar Bhavan, Hiranandani, Business Mumbai. Park, Powai, Mumbai, Maharashtra-400 076 Pan/Gir No. Aaccj7808G (Applicant) (Respondent) Assessee By Shri Ajit Jain / Shri Siddesh Chaugule / Shri Rishab Parekh, Ld. Ars Revenue By Shri Kiran Unavekar, Sr. Dr Date Of Hearing 05.03.2025 Date Of Pronouncement 21.05.2025 आदेश / Order Per Raj Kumar Chauhan, Jm: This Appeal Is Directed Against The Assessment Order Dated 26.06.2024 Passed By Assessment Unit (Hereinafter Referred As Ld. Ao) For Ay 2020-21 In Pursuance To The Direction Of Ld. Drp-1, Mumbai Dated 14.06.2024

Section 143(3)Section 144C(13)Section 43A

read with section 144C(13) of the Income Tax Act, 1961 ('the Act') pursuant to the directions issued by the Hon'ble Dispute Resolution Panel I ('learned DRP') on the following grounds: 1. Disallowance of foreign exchange loss on remittances under section 43AA of the Act amounting ... debited on expenditure side. The learned assessing officer disallowed the same holding that assessee could not furnish the complete detail. Before the learned dispute resolution panel the assessee evidences. Those evidences are uploaded on ITBA website and AO was asked to furnish the remand report. Before the passing

Humboldt Wedag India Private Ltd, New Delhi vs. DCIT Circle - 10(1), New Delhi

In the result, the appeal filed by the assessee is partly allowed

ITA 4726/DEL/2024[2021-22]Status: DisposedITAT Delhi21 May 2025AY 2021-22

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumarhumboldt Wedag India Private Ltd., Vs. Addl./Joint/Deputy/Asstt. A – 36, Mehtab House, Commission Of Income-Tax, Mohan Co-Op. Estate, Mathura Road, National E-Assessment Centre, New Delhi – 110 044. Circle 10(1), Delhi. (Pan : Aaach7474G) (Appellant) (Respondent) Assessee By : Shri Rajineesh Verma, Ca Ms. Hem Lata Verma, Ca Revenue By : Shri Dharam Veer Singh, Cit Dr Date Of Hearing : 09.04.2025 Date Of Order : 21.05.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Is Filed By The Assessee Against The Final Assessment Order Dated 05.09.2024 Passed U/S 143(3) R.W.S.144C (13) Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’) Subsequent To The Directions Of The Ld. Dispute Resolution Panel (Drp)/Tpo Vide Order Dated 07.08.2024 For Assessment Year 2021-22 Raising Following Grounds Of Appeal :- “Pertaining To Transfer Pricing Matters: Adjustment Rs.10,486,841 1. On The Facts & In The Circumstances Of The Case & In Law, The Learned Dispute Resolution Panel ('Ld. Drp'), The Learned Transfer Pricing

For Appellant: Shri Rajineesh Verma, CAFor Respondent: Shri Dharam Veer Singh, CIT DR
Section 143(3)Section 144CSection 144C(8)Section 153Section 234ASection 270ASection 92CSection 92C(2)

passed u/s 143(3) r.w.s.144C (13) of the Income Tax Act, 1961 (hereinafter called ‘the Act’) subsequent to the directions of the Ld. Dispute Resolution Panel (DRP)/TPO vide order dated 07.08.2024 for Assessment Year 2021-22 raising following grounds of appeal :- “Pertaining to Transfer Pricing Matters: Adjustment Rs.10 ... facts and in the circumstances of the case and in law, the Learned Dispute Resolution Panel ('Ld. DRP'), the Learned Transfer Pricing 2 Officer (Ld. TPO') and the Learned AO (collectively referred as "the Revenue") erred in making an adjustment of Rs.10,486,841 to the total income

Sri Kumawat Samaj Trust, Chennai vs. CIT, Exemptions, Chennai

In the result, the appeal filed by the assessee is dismissed

ITA 627/CHNY/2025[2020-21]Status: DisposedITAT Chennai14 May 2025AY 2020-21

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.627/Chny/2025 िनधा"रण वष"/Assessment Year: 2020-21 Sri Kumawat Samaj Trust, Vs. The Commissioner Of No. 14, 1St Floor, Kumarappa Street, Income Tax (Exemptions), Sevenwells, Chennai 600 001. Chennai. [Pan:Aavts7941K] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Naresh Singh Rathore, Ca ""थ" की ओर से/Respondent By : Shri Ar.V. Sreenivasan, Cit सुनवाई की तारीख/ Date Of Hearing : 29.04.2025 घोषणा की तारीख /Date Of Pronouncement : 14.05.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 29.12.2024 Passed By The Ld. Commissioner Of Income Tax (Exemption), Chennai For The Assessment Year 2020-21 Under Section 119(2)(B) Of The Income Tax Act, 1961 [“Act” In Short].

For Appellant: Shri Naresh Singh Rathore, CAFor Respondent: Shri AR.V. Sreenivasan, CIT
Section 111Section 115VSection 119(2)(b)Section 12ASection 132Section 132ASection 139Section 154Section 158BSection 250

under sub-section (3), of section 143 or section 147 or section 153A or section 153C in pursuance of the directions of the Dispute Resolution Panel or an order passed under section 154 in respect of such order; †or (e) an order passed by an Assessing Officer under sub-section