“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

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

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

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

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

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

Dana Anand India Private Limited, Pune vs. DCIT, Akurdi, Pune

ITA 1571/PUN/2024[2020-21]Status: DisposedITAT Pune04 Apr 2025AY 2020-21

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: Shri R D OnkarFor Respondent: Shri Ramnath P Murkunde

Section 143(1)(a)Section 143(3)Section 154Section 37Section 37(1)Section 41Section 41(1)Section 80ASection 80G

draft assessment order determining the total income at Rs.338,51,08,520/- by making certain other additions. 3. The assessee approached the Dispute Resolution Panel (DRP) who deleted the TP adjustment of Rs.1,64,17,30,653/-. So far as the other additions made by the Assessing Officer

Ras Lifesciences Private Limited, New Delhi vs. DCIT., Circle 3(1), Hyderabad

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

ITA 788/HYD/2024[2020-21]Status: DisposedITAT Hyderabad04 Apr 2025AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Vishal Kalra, AdvocateFor Respondent: : Smt. M. Narmada, CIT-DR

Section 143(3)Section 92C(3)

passed u/s.143(3) r.w.s. 144C(13) r.w.s 144B of the Income Tax Act, 1961 ('the Act'), as per the direction of Learned Dispute Resolution Panel, Bangalore (“Ld. DRP”) on 25.06.2024 for A.Y. 2020-21. 2. The assessee has raised the following grounds : “ 1. That on facts and circumstances ... against the returned loss of INR 9,44,44,121 in pursuance to the directions passed by the Dispute Resolution Panel ("DRP"). Adjustment relating to transaction of sale of goods ITA No.788/Hyd/2024 2 2. That on facts and circumstances of the case and in law, the AO/ DRP/Transfer Pricing Officer

Vibgyor Printing & Packaging (P) Ltd., Ahmedabad vs. A.C.I.T., CC-4(3), Kolkata

Appeal of the assessee is allowed

ITA 2615/KOL/2024[2021-2022]Status: DisposedITAT Kolkata04 Apr 2025AY 2021-2022

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 153Section 153BSection 3

order. 2. For the sake of convenience, the regular appeal is taken up first. It is seen in this case that the Ld. Dispute Resolution Panel (DRP) passed an order u/s 144C(5) of the Income Tax Act, 1961 (hereafter “the Act”), dated I.T.A. No. 2615/Kol/2024 SA No. 1/Kol/2025 Vibgyor ... issue to be decided is the point of initiation of limitation for passing a Final Assessment Order. Section 144C is entitled 'Reference to dispute resolution panel' and sets out the procedure for assessment in cases involving international 4 I.T.A. No. 2615/Kol/2024 SA No. 1/Kol/2025 Vibgyor Printing & Packaging (P) Ltd. transactions

Subramania Sreenivasa Ganeshanatha, Ruwi vs. Int Tax Ward 2(3)(1) Mumbai, Mumbai

Accordingly, Ground No.1 raised by the Revenue is dismissed

ITA 916/MUM/2025[2018-19]Status: DisposedITAT Mumbai04 Apr 2025AY 2018-19

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

For Appellant: Shri Hiran C. (Virtually Present)For Respondent: 02.04.2025

Section 10(38)Section 144C(13)Section 147Section 68Section 69ASection 69C

following grounds of appeal: “1. The order u/s 147 r.w.sec. 144C(13) passed by the Assessing Officer, though with the directions of the Disputes Resolution Panel, is contrary to law, facts and circumstances of the case. 2. The Appellant submits and states that there was neither search nor survey ... made an addition at 3% towards the commission as addition under section 69C of the Act. The assessee raised its objections before the Dispute Resolution Panel (DRP). The DRP rejected the contentions of the assessee and upheld the addition made by the AO. The assessee is in appeal before

ACIT Circle-26(1), Delhi vs. V&S Seair Logistics Pvt. Ltd., Delhi

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

ITA 785/DEL/2019[2014-15]Status: DisposedITAT Delhi04 Apr 2025AY 2014-15

Bench: Shri M Balaganesh & Shri Vimal Kumarassessment Year: 2022-23 Telstra Singapore Pte Ltd., Vs. Dcit, Circle-3(1)(1), 8 Cross Street, 22-00, Manulife International Taxation, Tower, Singapore New Delhi Pan :Aadct5366N (Appellant) (Respondent)

Section 143(3)Section 144CSection 270ASection 9(1)(vi)

Income Tax, Circle-3(1)(1) International Taxation, New Delhi ('the Id. AO') in pursuance of the directions of the Hon'ble Dispute Resolution Panel -2 (Hon'ble DRP) is wrong and bad in law, contrary to facts and circumstances of the case and unsustainable in law. 2. Based

Lesso Buildtech Private Limited, Gurgaon vs. The Dy.CIT, Circle-2(1)(1), Ahmedabad

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

ITA 1698/AHD/2024[2020-21]Status: DisposedITAT Ahmedabad03 Apr 2025AY 2020-21

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 143(1)Section 143(3)Section 144C(1)Section 92C

Profit determining the Total Income as per the above proposal as per normal provisions 4. Assessee filed objection in Form 35A before Dispute Resolution Panel on 16-10-2023. The DRP vide its order dated 05-06-2024 deleted the TP adjustment made by TPO. However on the issue ... raising the following Grounds of Appeal: 1. On the facts and in the circumstances of the case and in law, the Hon'ble Dispute Resolution Panel ('DRP') and the Ld. AO (hereinafter collectively to be referred as "Revenue") have erred in assessing the loss of the Appellant

Vayam Technologies Limited, New Delhi vs. DCIT Circle-25(1), New Delhi

In the result, appeal of the assessee is partly allowed

ITA 1476/DEL/2023[2012-13]Status: DisposedITAT Delhi03 Apr 2025AY 2012-13

Bench: SHRI SHAMIM YAHYA (Accountant Member), SHRI VIMAL KUMAR (Judicial Member)

Section 143(2)Section 144C(1)

Aggrieved by the Draft Assessment order dated 29.03.2024 passed u/s. 144C(1) of the Act, the assessee filed objections before the Dispute Resolution Panel (DRP). The DRP vide directions dated 29.12.2024 upheld the view of Assessing Officer and rejected assessee's objections. Thus, the AO in compliance with

Royal Canin India Private Limited, Mumbai vs. Assistant Commissioner of Income-Tax, Circle 3(1)(1), Mumbai

In the result, appeal of the assessee Ground no

ITA 4546/MUM/2024[2020-21]Status: DisposedITAT Mumbai01 Apr 2025AY 2020-21

Bench: Shri Amarjit Singh & Shri Anikesh Banerjee

For Appellant: Shri K.M. Gupta a/w Shri AnmolFor Respondent: Shri Pankaj Kumar (CIT DR)

Section 143(3)Section 144BSection 144CSection 144C(13)

Assessment Year 2020-21, date of order 12/07/2024. The said order was originated by the recommendation of the Learned CIT-(Dispute Resolution Panel-2), Mumbai-3 (in short, 'Ld.DRP') passed under section 144C (5) of the Act, date of order 12/06/2024. 2. The following are the grounds raised ... read with section 144C(13) of the Act by Ld. AO is not in conformity with the directions of the Hon'ble Dispute Resolution Panel-2, Mumbai ('Ld. DRP") and is liable to be quashed being in gross violation of the strict mandate of section 144C

Kgk Creations Private Limited, Mumbai vs. Circle 2(2)(1), Mumbai

In the result, ground No. 9 to 13 are allowed

ITA 6854/MUM/2024[2021-2022]Status: DisposedITAT Mumbai28 Mar 2025AY 2021-2022

Bench: Shri Pawan Singh & Shri Girish Agrawalkgk Creations Private Limited Jurisdiction Assessing Officer Gj-10, Seepz Sez, Seepz S.O. Vs. (Jao) Mumbai 400096, Circle 2(2)(1), Mumbai Aayakar Pan No. Aabck0378H Bhawan, Mumbai Appellant/ Assessee Respondent/ Revenue Assessee Represented By Shri Vijay Mehta Ca / Ar Department Represented By Shri Kiran Unavekar Sr. Dr. Date Of Hearing 17/03/2025 Date Of Pronouncement 28/03/2025

Section 143(3)Section 144BSection 144C(13)Section 254(1)

read with Section 144C(13) read with Section 144B of the Income Tax-Act, 1961, passed in pursuance of direction of Dispute Resolution Panel-2 New Delhi(DRP) dated 18.12.2023. The Assessee has raised following grounds: 1. “Based on the facts and circumstances of the case, the Appellant craves leave ... Assessment Order passed on 18/12/2023. The draft assessment order was served on the assessee. The assessee exercised its option to filed objection before Dispute Resolution Panel (DRP). The DRP upheld the order TPO in its order dated 30/09/2024. On receipt of direction of DRP, the Assessing Officer passed final Assessment

Vijay Kumaar Saraff, Mumbai vs. ITO, Int. Tax. Ward 4(2)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 630/MUM/2023[2017-18]Status: DisposedITAT Mumbai28 Mar 2025AY 2017-18

Bench: Shri Beena Pillai & Smt. Renu Jauhriआयकर अपील सं./Ita No. 630/Mum/2023 (निर्धारण वर्ा / Assessment Year :2017-18) Vijay Kumar Saraff V/S. Ito, Int Tax Ward 4(2)(1), B 303, Ashok Gardens, बिधम Mumbai Tokersi Jivraj Road Sewri, 1708, 17Th Floor, Air India Mumbai, Maharashtra- Building, Nariman Point, 400015 Mumbai-400021 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aajps2870H Appellant/अपीलधर्थी .. Respondent/प्रनिवधदी

For Appellant: Ms. Rutuja Pawar & Ms. SnehaFor Respondent: Shri Krishna Kumar

Section 143(1)Section 144C(5)Section 147Section 148Section 153Section 68

therefore, bad in law and illegal. 2. In the facts and circumstance of the Appellant's case the directions issued by Dispute Resolution Panel u/s 144C(5) of the Income-tax Act 1961 are bad in law. 3. In the facts and circumstance of the Appellant's case, initiating proceedings

Edenred Pte Ltd, Mumbai vs. Deputy Commissioner of Income Tax, International Taxation -2(2)1, Mumbai

Appeal is allowed

ITA 4334/MUM/2023[2021-22]Status: DisposedITAT Mumbai28 Mar 2025AY 2021-22

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

Section 143(3)Section 9(1)(vi)

under the India-Singapore DTAA, the AO has erred in changing his opinion with respect to the same nature of receipts. c) The Dispute Resolution Panel erred in directing the AO to follow its Directions of AY 2018-19 & AY 2019-20 for taxing Management Service fees as Royalty

Centrient Pharmaceuticals India Private Limited, Punjab vs. DCIT/ ACIT, Circle 1(1), Chandigarh

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

ITA 1201/CHANDI/2024[AY 2021-22]Status: DisposedITAT Chandigarh26 Mar 2025

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ I.T.A. No. 1201/Chd/2024 "नधा"रण वष" / Assessment Year: 2021-22

For Appellant: Sh. Darpan Kirpalani, AdvocateFor Respondent: Sh. Rohit Shrma, CIT, D.R. (Virtual)

Section 143(3)Section 144Section 144CSection 144C(10)Section 153(1)Section 253(1)(d)

read with section 144C read with section 1448 of the Act in pursuance of directions dated 26 September 2024 issued by Ld. Dispute Resolution Panel (DRP). In facts and circumstances of the case and in law, Ld. AO/ Transfer Pricing Officer (TPO) and Ld. DRP have: 1. erred in making ... Final Order passed by Ld. Assessing Officer ('Ld. AO) being passed not in conformity with the directions issued by the Dispute Resolution Panel ('Hon'ble DRP'), is bad in law as per provisions of section 144C(10) r.w.s. 144C(13) of the A.Y. 2021-22 3 Income

M/S. Sp Imperial Star Private Limited, Mumbai vs. ITO, Ward, 3(3)(3), Mumbai

In the result, the appeal filed by the assessee is allowed for statistical purpose

ITA 5862/MUM/2024[2021-22]Status: DisposedITAT Mumbai26 Mar 2025AY 2021-22

Bench: SHRI. AMARJIT SINGH (Accountant Member), MS. KAVITHA RAJAGOPAL (Judicial Member)

For Appellant: Shri. Dharan GandhiFor Respondent: Shri. Ajay Chandra, CIT DR

Section 143(3)Section 144C(5)Section 92Section 948Section 94B

passed u/s. 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (‘the Act'), pursuant to the direction of the Hon'ble Dispute Resolution Panel (‘Hon'ble DRP’ for short) dated 21.08.2024, u/s. 144C(5) of the Act, pertaining to Assessment Year (‘A.Y.’ for short ... learned Assessing officer (hereinafter referred to as "AO") /the learned Transfer Pricing Officer (hereinafter referred to as "TPO") /the Hon'ble Dispute Resolution Panel (hereinafter referred to as "DRP") have erred in law, facts and circumstances of the case by completely ignoring the revised Form 3CEB filed by the appellant

Jsw Energy Limited, Mumbai vs. The Assistant Commissioner of Income Tax, Central Circle 8(3), Mumbai

In the result, both the appeals are allowed partly for statistical

ITA 3714/MUM/2024[2020-21]Status: DisposedITAT Mumbai26 Mar 2025AY 2020-21

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Mr. Gaurav KabraFor Respondent: Ms. Neena Jeph, CIT-DR/

Section 115JSection 14ASection 37Section 80I

Central Circle 8(3), Mumbai [in short 'the Ld. Assessing Officer'], for assessment year 2020-21, pursuant to the direction of the Ld. Dispute Resolution Panel (DRP). As common issues in dispute are involved in these appeals, therefore, same were heard together and disposed off by way of this consolidated ... revised its ground No. 1 as under: On the facts and circumstances of the case as well as in law, the Hon'ble Dispute resolution Panel has erred in confirming the action of the Learned Assessing Officer in making an upward adjustment

Jsw Energy (Barmer) Limited, Mumbai vs. The Assistant Commissioner of Income Tax, Central Circle 8(3), Mumbai

In the result, both the appeals are allowed partly for statistical

ITA 3713/MUM/2024[2020-21]Status: DisposedITAT Mumbai26 Mar 2025AY 2020-21

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Ms. Neena Jeph, CIT-DR/For Respondent: Mr. Gaurav Kabra

Section 14A

Officer’], for assessment year 2020 Officer’], for assessment year 2020-21 ,pursuant to the direction of pursuant to the direction of the Ld. Dispute Resolution Panel (DRP) the Ld. Dispute Resolution Panel (DRP). As common . As common issues in dispute are involved in these appeals, therefore, same were heard volved ... case as well as in law, the On the facts and circumstances of the case as well as in law, the Hon'ble Dispute resolution Panel has erred in confirming the Hon'ble Dispute resolution Panel has erred in confirming the Hon'ble Dispute resolution Panel has erred in confirming

Liquidhub Analytics Pvt. Ltd. (Now Merged With Capgemini Technology Services India Ltd), Pune vs. NFAC, Pune

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

ITA 1952/PUN/2024[2020-21]Status: DisposedITAT Pune25 Mar 2025AY 2020-21

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2020-21

For Appellant: Shri Nikhil PathakFor Respondent: Smt Nilu Jaggi, CIT

Section 143Section 143(3)Section 144C(1)

disallowance of health and education cess at Rs.24,70,183/- determined the total income at Rs.29,53,41,873/-. 3. Before the Dispute Resolution Panel (DRP), the assessee apart from challenging the addition on account of TP adjustment as well as disallowance of health and education cess, challenged the validity ... case of the assessee. It is also pertinent to mention that in terms of sections 144C(8) of the Act, the Dispute Resolution Panel may confirm, reduce or enhance the variations proposed in the draft order so, however, that it shall not set aside any proposed variation or issue

Yugendiran Vishnupriya, Chennai vs. ITO, Ward-2(2), Chennai

The appeals of the assessee are allowed

ITA 3242/CHNY/2024[2017-18]Status: DisposedITAT Chennai25 Mar 2025AY 2017-18

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.3241 &3242/Chny/2024 (िनधा"रणवष" / Assessment Years: 2016-2017 & 2017-18) Yugendiran Vishnupriya Vs. Income Tax Officer, Door No.284/3, International Tax, Thiruveni Colony, Bellyarea, Ward 2(2) Anna Nagar, Chennai-600040 Chennai. [Pan: Apzpv 9903M] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Mr. Y. Sridhar, F.C.A ""यथ" क" ओर से /Respondent By : Mr. R. Clement Ramesh Kumar, Cit सुनवाई क" तार"ख/Date Of Hearing : 25.02.2025 घोषणा क" तार"ख /Date Of Pronouncement : 25.03.2025 आदेश / O R D E R Per Manu Kumar Giri ()

For Appellant: Mr. Y. Sridhar, F.C.A ""For Respondent: Mr. R. Clement Ramesh Kumar, CIT

Section 143(2)Section 144Section 144C(5)Section 147Section 148Section 5(2)Section 9

u/s.144 r.w.s. 144C(13) of the Income Tax Act, 1961 (‘the Act’ in short) by orders dated 22.03.2024 pursuant to the Dispute Resolution Panel-2 (‘DRP’ in short), Bengaluru, directions u/s 144C(5) dated 26.02.2024. 2. The registry has noted delay of 202 days in filing the appeals. Considering ... grounds of appeal for AYs 2016-17 and 2017-18: Grounds of appeal for assessment year 2016-2017 ‘’1. The order of the Dispute Resolution Panel against the draft assessment order by the Id. AO is contrary to law and facts and circumstances of the case

Yugendiran Vishnupriya, Chennai vs. ITO, Ward-2(2), Chennai

The appeals of the assessee are allowed

ITA 3241/CHNY/2024[2016-17]Status: DisposedITAT Chennai25 Mar 2025AY 2016-17

For Appellant: Mr. Y. Sridhar, F.C.A ""For Respondent: Mr. R. Clement Ramesh Kumar, CIT

Section 143(2)Section 144Section 144C(5)Section 147Section 148Section 5(2)Section 9

Gallagher Service Center LLP (Formerly Known As Gallagher Operations Support Services P Ltd), Pune vs. Assistant Commissioner of Income-Tax, NFAC, Delhi

In the result, the Ground Number 6 is Partly Allowed for Statistical purpose

ITA 679/PUN/2022[2018-19]Status: DisposedITAT Pune24 Mar 2025AY 2018-19

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.679/Pun/2022 िनधा"रण वष" / Assessment Year : 2018-19 Gallagher Services Center V Additional/Joint Llp, S Commissioner Of Income 401, Delta 2, Gigaspace It Tax. Park, Vimannagar, Pune – 411014. Pan: Aaqfg7417F Appellant/ Assessee Respondent /Revenue Assessee By Shri M.P.Lohia – Ar Revenue By Shri Prakash L Pathade – Cit(Dr) Date Of Hearing 23/01/2025 Date Of Pronouncement 24/03/2025 आदेश/ Order Per Dr.Dipak P.Ripote, Am : This Is An Appeal Filed By The Assessee Against The Assessment Order Of Passed Under Section 143(3) R.W.S 144C(3) Read With Section 144B Of The Income Tax Act, 1961; Dated 15.07.2022 For A.Y.2018-19. The Assessee Has Raised The Following Grounds Of Appeal : “Based On The Facts & Circumstances Of The Case, The Appellant Respectfully Craves Leave To Prefer An Appeal Under Section 253(1)(D)

Section 143(3)Section 144Section 144BSection 253(1)(d)

144C(13) read with section 1448 of the Act in pursuance of the directions dated 27 June 2022 issued by the Hon'ble Dispute Resolution Panel (hereinafter referred to as Hon'ble DRP), on the following grounds, which are independent of and without prejudice to each other, On the facts ... Pricing Officer’s order, the Assessing Officer passed a draft order under section 144C of the Act, dated 14.09.2021. Assessee filed appeal before Dispute Resolution Panel. The Dispute Resolution Panel(DRP) passed an order on 27.06.2022. Before the DRP, assessee submitted that assessee has entered into Bilateral Advanced Pricing Agreement

Utv Software Communications Pvt. Ltd, Mumbai vs. ACIT Cir 16(1), Mumbai

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

ITA 2524/MUM/2022[2018-19]Status: DisposedITAT Mumbai24 Mar 2025AY 2018-19

Bench: Shri. Narendra Kumar Billaiya, Am & Ms. Kavitha Rajagopal, Jm Utv Software Communications The Assistant Commissioner Of Private Limited Income Tax, Circle – 16(1) Room No. 467, 4Th Floor, Aayakar Star House, Urmi Estate, 95, Ganpatrao Vs. Kadam Marg, Lower Parel (W), Bhavan, Maharishi Karve Road, Mumbai – 400 013. Mumbai – 400020. Pan/Gir No. Aaacu4122G (Appellant) : (Respondent) Assessee By : Ms. Simran Keswani Respondent By : Shri. Pankaj Kumar, (Cit Dr) Date Of Hearing : 24.03.2025 Date Of Pronouncement : 24.03.2025 O R D E R Per Kavitha Rajagopal, J M: This Appeal Has Been Filed By The Assessee, Challenging The Final Assessment Order Dated 30.07.2022 Of The Learned Assessing Officer (‘Ld. Ao’ For Short), Passed U/S. 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961 (‘The Act'), Pursuant To The Direction Of The Hon'Ble Dispute Resolution Panel (‘Hon'Ble Drp’ For Short) Dated 29.06.2022 U/S. 144C(5) Of The Act, Pertaining To The Assessment Year (‘A.Y.’ For Short) 2018-19. 2. The Assessee Intends To Withdraw The Present Appeal & Had Made A Written Submission On March, 2025 To That Effect Stating That The Assessee Has Opted To Settle The Dispute Utv Software Communications Private Limited Through The Direct Tax Vivad Se Vishwas Scheme, 2024 Along With The Relevant Forms As Per The Dtvsv 2024 Scheme. 3. Upon Perusal Of The Same, We Deem It Fit To Dismiss The Appeal Filed By The Assessee As Withdrawn With The Liberty That The Assessee May Revive The Appeal If The Same Has Not Been Settled In The Dtvsv Scheme, If & When Necessary. 4. In The Result, The Appeal Filed By The Assessee Is Dismissed As Withdrawn. Order Pronounced In The Open Court On 24.03.2025 (Narendra Kumar Billaiya)Mumbai; Dated: 24.03.2025 Karishma J. Pawar (Stenographer) Copy Of The Order Forwarded To: 1. The Appellant 2. The Respondent 3. Cit- Concerned 4. Dr, Itat, Mumbai 5. Guard File By Order

For Appellant: Ms. Simran KeswaniFor Respondent: Shri. Pankaj Kumar, (CIT DR)

Section 143(3)Section 144C(5)

passed u/s. 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (‘the Act'), pursuant to the direction of the Hon'ble Dispute Resolution Panel (‘Hon'ble DRP’ for short) dated 29.06.2022 u/s. 144C(5) of the Act, pertaining to the Assessment Year (‘A.Y.’ for short