← All Phrases

“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

Pralhad Vasantrao Mulick, Pune, Maharashtra vs. The ITO, (It) Ward-3, Pune, Maharashtra

In the result, appeal of the assessee is allowed

ITA 452/PUN/2025[2015-2016]Status: DisposedITAT Pune05 May 2025AY 2015-2016
Section 139(1)Section 147Section 148Section 148ASection 69

Assessment Year 2015-16. The assessee has raised the following grounds of appeal : “1. The learned Assessing Officer acting under directions of leaned Dispute Resolution Panel erred both on facts and in law in confirming the addition of Rs.1,09,78,640 u/s 69 of the Act alleging unexplained investments ... account of investment in immoveable property i.e.Flat No.401, Pratham Apartment, Pune. Aggrieved by the assessment order, Assessee filed objections before Dispute Resolution Panel. Assessee made an elaborate submission before Dispute Resolution Panel(DRP). The DRP called for a Remand Report from the Assessing Officer. The Assessing Officer submitted Remand Report

Dsm Shared Services India Private Limited, Hyderabad vs. ACIT, Circle-8(1), Hyderabad

In the result, the appeal of the assessee is partly allowed for statistical purpose

ITA 501/HYD/2022[2018-19]Status: DisposedITAT Hyderabad05 May 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Aliasgar Rampurawala, C.AFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 143(3)Section 43B

Officer ("Ld. AO") passed u/s.143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 ('the Act'), as per the direction of Learned Dispute Resolution Panel-1, Bangalore (“Ld. DRP”) on 30.07.2022 for A.Y. 2018-19. 2. The assessee has raised the following grounds of appeal : ITA No.501/Hyd/2022 ... learned Assessing Officer ('AO') /Transfer Pricing Officer ('TPO') erred by not giving effect to the rectified directions of the Dispute Resolution Panel dated 27 January 2023 to exclude Access Healthcare Services Pvt. Ltd. from the final set selected by the TPO for benchmarking of Information technology enabled services provided

Gainsight Software Private Limited, Hyderabad vs. Deputy Commissioner of Income Tax, Circle 2(1), Hyderabad

In the result, the appeal of the assessee is partly allowed for statistical

ITA 200/HYD/2021[2016-17]Status: DisposedITAT Hyderabad05 May 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Aliasgar Rampurawala, C.AFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 143(3)Section 271ASection 37(1)Section 438

u/s.143(3) r.w.s. 144C(13),143(3A) & 143(3B) of the Income Tax Act, 1961 (‘the Act’), as per the direction of Learned Dispute Resolution Panel-1, Bangalore (“Ld. DRP”) on 30.03.2021 for A.Y. 2016-17. 2. The assessee has raised the following grounds of appeal : ITA No.200/Hyd/2021 ... each other and without prejudice to one another. 1. Onthe facts and in the cireumstances of the case and in law, the Learned Dispute Resolution Panel (Ld. DRP’) erred in upholding the action of the Learned Assessing Officer (Ld. AO’) / Learned ‘lransfer P ng Officer (Ld. TPO’) in making

Open Text Technologies India Private Limited, Hyderabad vs. Dy. Commissioner of Income Tax, Circle-16(2), Hyderabad

ITA 2387/HYD/2018[2014-15]Status: DisposedITAT Hyderabad05 May 2025AY 2014-15

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Madhusudan Sawdia, Hon'Ble

For Appellant: Revenue byFor Respondent: Date of hearing
Section 143(3)Section 92B

92CA(3) & 144(C)(1) of the Income Tax Act, 1961 (“the Act”) on 29.10.2018 as per the direction of Learned Dispute Resolution Panel ("Ld. DRP") dated 27.08.2018 for the A.Y. 2014-15. 2. The assessee has raised the following grounds of appeal : “1. Rejection of transfer pricing documentation maintained

Wns Global Services Private Limited, Mumbai vs. Asessment Unit, National Faceless Assessment Centre, New Delhi

In the result, the appeal of the assessee bearing ITA No

ITA 4432/MUM/2024[AY 2020-2021]Status: DisposedITAT Mumbai05 May 2025

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankarwns Global Services Private Vs Assessment Unit, National Faceless Limited, Mumbai Assessment Centre, New Delhi Pl-10/11, Gate No.4, Godrej- Boyce Complex, Pirojshanagar, L.B.S.Marg, Vikhroli (West), Mumbai-400 079 Pan: Aaacw2598L Appellant Respondent

For Appellant: ShriPorus Kaka A/w Manish KanthFor Respondent: Shri Pankaj Kumar (CIT DR)
Section 143(3)Section 144BSection 144CSection 144C(13)Section 144C(5)Section 253

Assessment Unit, National Faceless Assessment Centre ('AO') dated 18 June 2024 ('Final Assessment order") in pursuance of the directions issued by Dispute Resolution Panel-2 (DRP), Mumbai dated 3 May 2024 (DRP Directions") on the following grounds which are independent and without prejudice to each other. General Ground ... order dated 18 June 2024 passed by the Assessing Officer under section 144C(13) without giving effect to the binding directions of the Dispute Resolution Panel ("DRP') is bad in law and is liable to be quashed. Transfer Pricing Grounds 3 ITA 4432/Mum/2024 WNS Global Service Private Limited

International Seaport Dredging Limited, Chennai vs. DCIT, Chennai

The appeal stand allowed

ITA 72/CHNY/2018[2013-14]Status: DisposedITAT Chennai02 May 2025AY 2013-14

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकर अपील सं./ Ita No.72/Chny/2018 (िनधा)रणवष) / Assessment Year: 2013-14) & आयकर अपील सं./ It (Tp)A No.35/Chny/2018 (िनधा)रणवष) / Assessment Year: 2014-15) & आयकर अपील सं./ It (Tp)A No.87/Chny/2019 (िनधा)रणवष) / Assessment Year: 2015-16) M/S. International Seaport Dredging Dcit / Jcit(Osd) Private Limited, Corporate Circle-2(2) बनाम 5Th Floor, Challam Towers, Chennai. Old No.62, New No.113, / Vs. Dr.Radhakrishnan Salai Chennai-600 004. "थायीलेखासं./जीआइआरसं./Pan/Tan No. Aabci-2286-E (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Ashik Shah (C.A) – Ld.Ar ""थ"कीओरसे/Respondent By : Shri A.Sasi Kumar (Cit) -Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 05-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 02-05-2025 आदेश / O R D E R Per Manu Kumar Giri, Jm: These Appeals By Assessee For Assessment Years (Ay) 2013-14 & 2014-15 Arise Out Of The Separate Orders Of Assessments Framed By Ld.

For Appellant: Shri Ashik Shah (C.A) – Ld.ARFor Respondent: Shri A.Sasi Kumar (CIT) -Ld. DR
Section 143(3)

made certain adjustments / disallowances to the assessee's income. Against draft assessment order of the AO, the Appellant filed its objections before the Dispute Resolution Panel ('DRP' in short) for AY 2013-14 and 2014-15. The DRP deleted the transfer pricing adjustment towards lease rental payments

Farfetch India Private Limited, Delhi vs. Income Tax Officer, National Faceless Assessment, Delhi

In the result, the appeal of the assessee is dismissed as withdrawn

ITA 5555/DEL/2024[AY 2021-22]Status: DisposedITAT Delhi02 May 2025

Bench: Shri Mahavir Singh & Shri Pradip Kumar Kedia[Assessment Year : 2021-22] Farfetch India Pvt.Ltd. Vs Ito 333, 3Rd Floor, Devika Tower 6 National Faceless Nehru Place, South Delhi Assessment Centre New Delhi-110019 Delhi Pan-Aadcf3785H Appellant Respondent Appellant By None Respondent By Shri Rajesh Dhanesta, Sr.Dr Date Of Hearing 02.05.2025 Date Of Pronouncement 02.05.2025 Order

Section 143(3)

passed u/s 143(3) r.w.s 144C(13) r.w.s 144B of the Act pertaining to assessment year 2021-22 in pursuance of direction of Dispute Resolution Panel-2, New Delhi (“DRP”) dated 30.09.2024 . 2. At the time of hearing, no one attended on behalf of the assessee. Vide letter dated

Vinod Kumar Jangir, Jhunjhunu vs. Dct, Circle (Intl Tax), Jaipur

Appeal is allowed and the impugned assessment

ITA 779/JPR/2024[2013-14]Status: DisposedITAT Jaipur01 May 2025AY 2013-14

Bench: Shri Gagan Goyal & Shri Narinder Kumarmr. Vinod Kumar Jangir, C/O. Yashi Super Market, Vishwakarma Complex, Gandhi Chowk, Distt. Jhunjhunu -333001 Pan No. Arzpj 7960G ...... Appellant Vs.

For Appellant: Mr. R. S. Poonia, C.A., Ld. ARFor Respondent: Mrs. Alka Gautam, CIT, Ld. DR
Section 139(4)Section 144CSection 147Section 148Section 148ASection 69

144C (1) of the Act and proposed an addition of Rs. 55 Lacs. Against this draft assessment order the assessee approached the Dispute Resolution Panel-1, New Delhi (DRP). The DRP confirmed the draft order passed u/s. 144C (1) and issued the direction for final assessment order u/s. 144C

M/S. Philips Electronics Nederland B.V., Kolkata vs. A.C.I.T.(International Taxation), Circle - 2(1), Kolkata

In the result, appeal of the assessee is allowed

ITA 134/KOL/2023[2020-2021]Status: DisposedITAT Kolkata30 Apr 2025AY 2020-2021

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarmaआयकर अपील सं/Ita No.134/Kol/2023 (नििाारण वर्ा / Assessment Year : 2020-2021) M/S Philips Electronics Vs Acit(International Taxation), Nederland B.V. Circle-2(1), Kolkata C/O Deloitte Haskins & Sells Llp Bengal Intelligent Park, Building Omega, 13Th& 14Th Floor, Block- Ep & Gp, Sector-V, Salt Lake Electronic Complex, Kolkata- 700091 Pan No. :Aafcp4361F (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररतीकीओरसे /Assessee By : Shri Ketan Ved, Ar राजस्वकीओरसे /Revenue By : Shri Guru Bhashyam, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 06/02/2025 घोषणा की तारीख/Date Of Pronouncement : 30/04/2025 आदेश / O R D E R Per Rajesh Kumar, Am: This Is An Appeal Filed By The Assessee Against The Order Dated 31.12.2022, Passed By The Acit, Circle-2(1), It, Kolkata Giving Effect To The Direction Given By The Dispute Resolution Panel-2, New Delhi(In Short The ‘Drp’), Dated 04.11.2022, Thereby Finalizing The Assessment Order In Accordance With The Provisions Of Section 144C(13) R.W.S. 143(3) Of The Act. 2. At The Outset, Ld. Ar Drew Our Attention To The Additional Ground Filed By The Assessee & Submitted That The Appeal Of The Assessee May Be Decided On The Following Additional Grounds Taken By The Assessee :-

For Appellant: Shri Ketan Ved, ARFor Respondent: Shri Guru Bhashyam, CIT-DR
Section 142(1)Section 143(2)Section 143(3)Section 144CSection 144C(13)Section 156Section 90(2)

assessee against the order dated 31.12.2022, passed by the ACIT, Circle-2(1), IT, Kolkata giving effect to the direction given by the Dispute Resolution Panel-2, New Delhi(in short the ‘DRP’), dated 04.11.2022, thereby finalizing the assessment order in accordance with the provisions of Section 144C(13) r.w.s ... decided on the following additional grounds taken by the assessee :- 2 1:0 Re.: Validity of the Directions issued by the Dispute Resolution Panel: 1:1 The Appellant submits that considering the facts and circumstances of its case and the law prevailing on the subject, the Directions dated 14 November

Eviden India Private Limited (Formerly Known As Atos India Private Limited), Mumbai vs. Jurisdictional AO - DCIT, Circle 14(1)(1), Mumbai Assessment Unit, Income Tax Dept, Mumbai

In the result, appeal of the assessee is dismissed as withdrawn

ITA 6741/MUM/2024[2021-22]Status: DisposedITAT Mumbai29 Apr 2025AY 2021-22

Bench: Shri Pawan Singh, Hon’Bleshri Girish Agrawal, Hon’Bleeviden India Private Limited V. Dcit – 14(1)(1) Room No. 432, 4Th Floor (Formerly Known As Atos India Private Limited) Aayakar Bhavan Unit No. 1402 & 1403, Supremus, E Wing M.K. Marg - 400020 I Think Techno Campus, Kanjurmarg East Maharashtra Mumbai – 400042, Maharashtra Pan No. Aaaco2461J (Appellant) (Respondent) Assessee Represented By : Ms. Kinjal Patel Ca Department Represented By : Shri Ajey Kumar Ojha, Sr.Dr Date Of Conclusion Of Hearing : 29.04.2025 Date Of Pronouncement Of Order : 29.04.2025 Order Under Section 254(1) Of Income Tax Act Per Pawan Singh;

Section 143rSection 254(1)

assessee is directed against the assessment order passed under section 143rws 144C(13) dated 22.10.2024, passed in pursuance of directions of Dispute Resolution Panel (DRP). 2. This appeal was listed for hearing on 29.04.2025, the Learned Authorised Representative (Ld.AR) of the assessee submitted that due to inadvertence assessee has filed

International Air Transport Association, Mumbai (for Sending Notices) vs. Deputy Commissioner of Income Tax (International Taxation) - Circle 2(2)(1), Mumbai

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 3330/MUM/2023[2020-21]Status: DisposedITAT Mumbai29 Apr 2025AY 2020-21

Bench: Smt. Beena Pillai & Smt. Renu Jauhriआयकर अपील सं./Ita No. 3330/Mum/2023 (निर्धारण वर्ा / Assessment Year :2020-21) International Air V/S. Dcit (It), Circle 2(2)(1), Transport Association बिधम Mumbai C/O Ernst & Young Llp Room No. 1722, 17Th Floor, 14Th Floor, The Ruby, 29, Air India Building, Senapati Bapat Marg, Nariman Point, Mumbai, Dadar (West), Mumbai, Maharashtra-400021 Maharashtra-400028 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aacci4695N Appellant/अपीलधर्थी .. Respondent/प्रनिवधदी

For Appellant: Shri Porus Kaka and Shri DiveshFor Respondent: Shri Krishna Kumar

making P a g e | 5 A.Y. 2020-21 International Air Transport Association various additions based on the directions received from the Ld. Dispute Resolution Panel (DRP). The assessee has raised several grounds of appeal, which are discussed below: 4. Ground No. 1 – Provisions of distance learning course (addition ... between the ATCs and the students was on an independent basis and IATA Canada was not a privy to the said arrangement. The Dispute Resolution Panel (DRP) in IATA Canada's own case in AYs 2011-12 (Para 6.2.4 on Page 14 of the DRP Directions), 2016-17 (Para

DCIT (International Taxation), Dehradun vs. M/S. Bg Exploration & Production (India) Ltd., Dehradun

Appeal is dismissed

ITA 2134/DEL/2016[2006-07]Status: DisposedITAT Dehradun28 Apr 2025AY 2006-07

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

For Appellant: Sh. Amit Arora, Adv. &For Respondent: Sh. Mithun Shete, Sr. DR
Section 143(3)Section 42(1)Section 42(1)(b)Section 44C

several other reasons for joint-venture partners to not to share the expenditure. The Ld. Assessing Officer as well as the Ld. Dispute Resolution Panel, despite having the necessary details of the expenditure did not point out the single instance that these expenditure are not incurred by the Assessee ... Exploration & Production (India) Ltd. available with them they have denied the claim to the Assessee. Neither the assessing officer and nor the Dispute resolution Panel point out nature of details which was not submitted by the Assessee when part of the expenditure has already been considered in detail

Infoobjects Software India Private Limited, Jaipur vs. Deputy Commissioner of Income Tax, Circle 4, Jaipur

In the result, the appeal of the assessee is allowed

ITA 1499/JPR/2024[2021-22]Status: DisposedITAT Jaipur28 Apr 2025AY 2021-22

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकर अपील सं. / ITA No. 1499/JP/2024 निर्धारण वर्ष / Assessment Year : 2021-22 Infoobjects Software India Vs. Deputy Commissioner of Private Ltd. Income Tax, 5-E Patrikayan, 3rd Floor Jhalana Circle-04, Jaipur Institutional Area, Jaipur स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: AABCI8663B अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से/ Assessee by : Sh. Naman Maloo, CA राजस्व की ओर से / Revenue by

For Appellant: Sh. Naman Maloo, CAFor Respondent: Sh. P. P. Meena, CIT
Section 143(3)Section 144CSection 144C(5)Section 201Section 40Section 92B(2)

assessment year 2021-22. That order of assessment was passed after 2 Infoobjects Software India Pvt. Ltd. vs. DCIT considering the direction of Dispute Resolution Panel [ in short “DRP’] passed under Section 144C(5) of the Act dated 27.09.2024. 2. In this appeal, the assessee has raised the following grounds ... section 144C read with section 144B of the Income Tax Act, 1961 dated 28.12.2023. The assessee filed an objection before the Hon'ble Dispute Resolution Panel [ for short DRP ] against the draft order. After considering the submission of the assessee, the Hon'ble DRP has passed order vide dated

Royal Canin India Private Limited, Mumbai vs. Assistant Commissioner of Income-Tax, Mumbai

Appeal is hereby dismissed

ITA 6816/MUM/2024[2021-22]Status: DisposedITAT Mumbai28 Apr 2025AY 2021-22

Bench: Shrivikram Singh Yadav & Shri Anikesh Banerjeeroyal Canin India Pvt Ltd Vs Assistant Commissioner Of Income- 1401 & 1402, F Wing, 14Th Tax, Circle 3(1)(1), Floor, Lotus Corporate Park, Aayakar Bhavan, M.K. Road, Cts No.185/A, Graham Firth Mumbai-400 020 Compound, Western Express Highway, Goregaon (East), Mumbai-400 063 Pan: Aadcr4417J Appellant Respondent

For Appellant: ShriK.M. Gupta a/w Shri AnmolFor Respondent: Shri Pankaj Kumar (CIT DR)
Section 143(3)Section 144BSection 144CSection 144C(13)

short, ‘the Act’), for Assessment Year 2021-22, date of order 22/10/2024. The said order was originated by the recommendation of theCIT-Dispute Resolution Panel-2, Mumbai-3 (in short, ‘Ld.DRP’) passed under section 144C (5) of the Act, date of order 16/09/2024. 2. The following are the grounds raised ... read with section 144C(13) of the Act by the Ld. AD is not in conformity with the directions of the Hon'ble Dispute Resolution Panel-2. Mumbai (Hon'ble DRP) and is liable to be quashed being in gross violation of the strict mandate of section 144C

Deputy Commissioner of Income Tax (It), Circle-2(2), Bengaluru vs. Telekom Malaysia Behard, Malaysia

In the result, appeal filed by the revenue is dismissed

ITA 2432/BANG/2024[2012-13]Status: DisposedITAT Bangalore25 Apr 2025AY 2012-13

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: Sri Manju Prasad, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 201(1)Section 250Section 9

response, the assessee filed a letter dated 28 October 2021, stating its intention to not file any objections before the ld. Dispute Resolution Panel (“DRP”) and reserving its right to file an appeal before the CIT(A) against the final assessment order. Additionally, the assessee also requested the learned

Xl Health Corporation India Private Limited, Bengaluru vs. Assistant Commissioner of Income Tax, Circle-7(1)(1), Bangalore

The appeals of the assessee are dismissed as withdrawn

ITA 420/BANG/2022[2017-18]Status: DisposedITAT Bangalore24 Apr 2025AY 2017-18

Bench: Shri Prashant Maharishi & Shri Prakash Chand Yadav

For Appellant: Shri Prathik Rath, AdvocateFor Respondent: Smt. Nandini Das, CIT(DR)(ITAT), Bengaluru
Section 143(3)

assessment years 2017-18 & 2018-19 IT(TP)A No.420/Bang/2024 Page 2 of 2 in pursuance of the ld. Dispute Resolution Panel’s (DRP) order dated 27.01.2022 & 14.6.2022 respectively. 2. At the outset, the ld. counsel for the assessee invited attention to the assessee’s letter dated 13.1.2025 stating that

Fluor Daniel India P.Ltd, New Delhi vs. Addl.CIT, Special Range-3, New Delhi

In the result, the appeals of the assessee in ITA Nos

ITA 6581/DEL/2018[2014-15]Status: DisposedITAT Delhi23 Apr 2025AY 2014-15

Bench: Shri Anubhav Sharma & Shri Naveen Chandra

For Appellant: Shri Vishal Kalra, AdvFor Respondent: Shri Om Prakash, CIT-DR
Section 143(3)Section 144CSection 271Section 92C

computation of the arm's length price ('ALP'), as required under section 92CA(1) of the Act; 3. The Ld. AO/Ld. TPO/Hon'ble Dispute Resolution Panel ('DRP') erred on facts and in law in making an upward adjustment on account of alleged interest on perceived delay in collection of receivables ... conformity with the TPO order. 9. Being aggrieved by the draft order, the assessee filed objections before the Dispute Resolution Panel (DRP). The DRP, vide directions dated 20.06.2018, directed the TPO to recompute the adjustment using interest rate of six months LIBOR plus 400 basis points on receivables where repayment

Bravura Solutions India LLP, New Delhi vs. Deputy Commissioner of Income Tax, New Delhi

In the result, the appeal of the assessee is partly allowed

ITA 3944/DEL/2024[2020-21]Status: DisposedITAT Delhi22 Apr 2025AY 2020-21

Bench: Shri Mahavir Singh & Shri M. Balaganeshbravura Solutions India Llp, Vs. Assessment Unit, P-24, Green Park Extension, Income Tax New Delhi-110016 Department, (Appellant) (Respondent) Pan: Aaqfb3843C

For Appellant: Shri Ajay Jain, ARFor Respondent: Shri Dharm Veer Singh, CIT DR
Section 143(3)Section 144BSection 144C(13)Section 144C(3)Section 92BSection 92C

appeal sought to set aside the impugned order dated 29.04.2024 passed by the Assessing Officer (AO) inconsonance with the order passed by the Dispute Resolution Panel (DRP) dated 12.06.2024 and order passed by Transfer Pricing Officer (TPO) under section 92CA(3) dated 25.07.2023 under section 143(3) read with section

Shakti Hormann Private Limited, Hyderabad vs. DCIT Circle -3(1), Hyderabad

In the result, appeals filed by the assessee for both the assessment years 2017-18 and 2018-19 are partly allowed

ITA 452/HYD/2022[2018-19]Status: DisposedITAT Hyderabad21 Apr 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita-Tp No.451/Hyd/2022 & 452/Hyd/2022 (निर्धारण वर्ा/Assessment Year: 2017-18 & 2018-19) Shakti Hormann Private Vs. Asst.Commissioner Of Limited Income Tax Hyderabad Circle-3(1) [Pan : Aadcs4024Q] Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri P.Murali Mohan Rao, Ar रधजस् व द्वधरध/Revenue By: Shri B.Bala Krishna, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 15/04/2025 घोर्णध की तधरीख/ 21/04/2025 Date Of Pronouncement: आदेश / Order Per Vijay Pal Rao: These Appeals Filed By The Assessee Are Directed Against The Assessment Orders Dated 21.07.2022 & 28.07.2022 Passed U/S 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961 (“The Act”) In Pursuant To The Directions Of The Dispute Resolution Panel (“The Drp”) U/S 144C(5) Of The Act For The Assessment Year 2017-18 & 2018-19 Respectively. 2. For The Assessment Year 2017-18, The Assessee Has Raised The Following Grounds Of Appeal :

For Appellant: Shri P.Murali Mohan Rao, ARFor Respondent: Shri B.Bala Krishna, CIT-DR
Section 143(3)Section 144C(5)Section 92C

passed u/s 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (“the Act”) in pursuant to the directions of the Dispute Resolution Panel (“the DRP”) u/s 144C(5) of the Act for the assessment year 2017-18 and 2018-19 respectively. 2. For the assessment year ... rate. The issue contested was rate of LIBOR, the actual LIBOR rate as per the assessee was 4-l2 per cent whereas the Dispute Resolution Panel has taken LIBOR at 5.7 per cent. The Tribunal has directed the Assessing Officer to examine the correct rate of LIBOR and adopt LIBOR

Tupperware India Private Limited, New Delhi vs. DCIT, Circle-25(1), New Delhi

In the result, the appeal of the assessee for AY 2018-19 is partly allowed for statistical purposes

ITA 462/DEL/2022[2017-18]Status: DisposedITAT Delhi17 Apr 2025AY 2017-18

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Rohit Tiwari, AdvFor Respondent: Shri S. K. Jadav, CIT DR
Section 143(3)Section 144BSection 144CSection 144C(3)Section 92CSection 92F

passed by the Assessing Officer (AO) inconsonance with the order passed by the Dispute Resolution Panel (DRP) dated 23.11.2021 and 07.06.2022 and order passed by Transfer Pricing Officer (TPO) under section 92CA(3) under section 143(3) read with section 144C(3) read with section 144B of the Income ... Learned Assessing Officer ("Ld. AO") under section 143(3) read with section 144C of the act pursuant to the directions of Learned Dispute Resolution Panel ("Ld. DRP") is bad in law and void-ab- initio as it is not in conformity with the provisions of section 144C