“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

Owens Corning (Singapore) Private Limited, Mumbai vs. The Deputy Commissioner of Income Tax (International Taxation) Circle-3(2)(2), Mumbai

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

ITA 4629/MUM/2023[2021-22]Status: DisposedITAT Mumbai18 Feb 2025AY 2021-22

Bench: Shri Amit Shukla, Hon’Ble & Shri Amarjit Singh, Hon’Bleassessment Year: 2021-22 Owens Corning (Singapore) Dcit (International Private Limited Tax), Circle-3(2)(2), Mumbai. C/O. Owens Corning (India) Pvt. Vs Limited, 7Th Floor, Alpha Building, Hiranandani Gardens, Powai, Maharashtra-400076. Pan: Aabco 5666 L (Appellant) (Respondent)

For Appellant: Shri Sandeep BhallaFor Respondent: Shri Krishna Kumar (Sr. DR)

Section 115ASection 143(2)Section 234Section 234ASection 234BSection 9(1)(vii)Section 90(2)

raised the following ground of appeal: 1.0 Re.: Treating fabrication charges received as 'fees for technical services': 1.1 The Assessing Officer ('AO')/ Dispute Resolution Panel ('DRP') has erred in taxing the fabrication charges received by the Appellant of Rs. 15,42,75,210 during the year under consideration by treating

Feedertech Pte Lyd, Nerul, Navi Mumbai vs. Assistant Commissioner of Income Tax, Nariman Point

ITA 4206/MUM/2023[2018-19]Status: DisposedITAT Mumbai18 Feb 2025AY 2018-19

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

For Appellant: Shri M.P. Lohia, ARFor Respondent: Shri Krishna Kumar, Sr. DR

Section 143(3)Section 144CSection 15Section 234BSection 234CSection 44B

144C(15) of the Act. Therefore, before proceeding further let us look at the provisions of section 144C of the Act. Reference to dispute resolution panel. 144C. (1) The Assessing Officer shall, notwithstanding anything to the contrary contained in this Act, in the first instance, forward a draft

Abb Switzerland Ltd., Bangalore vs. DCIT (It)-1(1)(1), Mumbai

In the result, all four appeals of the assessee are dismissed as withdrawn

ITA 776/MUM/2019[2014-15]Status: DisposedITAT Mumbai18 Feb 2025AY 2014-15

Bench: Smt. Beena Pillai & Smt. Renu Jauhri

For Appellant: Ms. Vasanti PatelFor Respondent: Shri Vinod Tanwani

Section 139(1)Section 234ASection 234BSection 234DSection 250

erred in initiating penalty proceedings under section 271(1)(c) and 271A of the Act. 11. Directions issued by the Honorable Dispute Resolution Panel ['DRP'] a) The DRP has erred in law and in facts in not taking cognizance of the objections filed by the Appellant in relation

Vodafone Idea Limited (Earlier Known As Vodafone India Ltd. Which Stands Merged With Idea Cellular Ltd. and Consequently Known As Idea Ltd.), Mumbai vs. ACIT - Circle- 5 (3)(2), Mumbai

Appeal are allowed for statistical purposes

ITA 316/MUM/2019[2014-15]Status: DisposedITAT Mumbai18 Feb 2025AY 2014-15

Bench: SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Ketan Ved; Shri Ninad PatadeFor Respondent: Date

Section 115JSection 143(3)Section 144CSection 144C(13)Section 144C(5)Section 14ASection 194HSection 32(1)Section 40Section 92C

Section 92CA and 144C(13) of the Income Tax Act, 1961 [hereinafter referred to as ‘the Act’], as per the direction issued by Dispute Resolution Panel (2), Mumbai [for short ‘DRP’] on 25/09/2018 under Section 144C(5) of the Act for the Assessment Year 2014-2015. 2. The Appellant ... A.Y.2014-2015 5. Transfer Pricing ('TP') adjustment-General Grounds 5.1. On the facts and circumstances of the case and in law, the Hon'ble Dispute Resolution Panel ('learned DRP") has erred in confirming the adjustments aggregating to INR 39,27,36,605 made by the Additional Commissioner of Income Tax, Transfer

Abb Switzerland Ltd, Bangalore vs. DCIT (I) 1(1)(1), Mumbai

In the result, all four appeals of the assessee are dismissed as withdrawn

ITA 790/MUM/2016[2012-13]Status: DisposedITAT Mumbai18 Feb 2025AY 2012-13

Bench: Smt. Beena Pillai & Smt. Renu Jauhri

For Appellant: Ms. Vasanti PatelFor Respondent: Shri Vinod Tanwani

Section 139(1)Section 234ASection 234BSection 234DSection 250

Abb Switzerland Ltd, Bangalore vs. DCIT (It) 1(1)(1), Mumbai

In the result, all four appeals of the assessee are dismissed as withdrawn

ITA 940/MUM/2015[2011-12]Status: DisposedITAT Mumbai18 Feb 2025AY 2011-12

Bench: Smt. Beena Pillai & Smt. Renu Jauhri

For Appellant: Ms. Vasanti PatelFor Respondent: Shri Vinod Tanwani

Section 139(1)Section 234ASection 234BSection 234DSection 250

Abb Switzerland Ltd, Bangalore vs. Asst DIT (It) 1(1), Mumbai

In the result, all four appeals of the assessee are dismissed as withdrawn

ITA 2180/MUM/2014[2010-11]Status: DisposedITAT Mumbai18 Feb 2025AY 2010-11

Bench: Smt. Beena Pillai & Smt. Renu Jauhri

For Appellant: Ms. Vasanti PatelFor Respondent: Shri Vinod Tanwani

Section 139(1)Section 234ASection 234BSection 234DSection 250

Ester Industries Ltd., New Delhi vs. ACIT, Delhi

In the result, appeals of the assessee are partly allowed

ITA 3618/DEL/2023[AY 2020-21]Status: DisposedITAT Delhi18 Feb 2025

Bench: Shri Challa Nagendra Prasad & Shri S Rifaur Rahmanassessment Year: 2008-09 बनाम Btl Industries Ltd., Dcit, (Merged With & Now Known As Vs. Central Circle-Ii, M/S Btl Holding Co. Ltd.), Faridabad, C/O Srs Mall, Third Floor, Haryana. Sector-12, Faridabad, Haryana. Pan No.Aaccb0573C अपीलाथ" Appellant ""यथ"/Respondent &

Section 143(2)Section 14ASection 153Section 153ASection 153A(1)(b)Section 234B

made. Accordingly, a draft assessment order was framed by the AO on 31.03.2014. 8. Qua this, respondent/assessee preferred its objections with the Dispute Resolution Panel (DRP). The DRP dismissed the objections on 21.10.2014. It is pursuant to the dismissal of the respondent/assessee’s objection, that the AO framed the assessment

Atkins Realis Uk Limited (Formerly Known As Atkins Limited), United Kingdom vs. The Deputy Commissioner of Income-Tax, International Taxation, Circle-1(1), Bangalore

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

ITA 907/BANG/2023[2021-22]Status: DisposedITAT Bangalore17 Feb 2025AY 2021-22

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Sharath Rao, CAFor Respondent: Ms. Neera Malhotra, CIT (DR)

rate. The draft assessment order was passed under Section 144C of the Act, allowing the assessee to file objections with the Dispute Resolution Panel if desired. 7. The assessee preferred to file objection before the learned DRP. The assessee argued before the learned DRP that the GIS charges levied

Aveva Information Technology India Private Limited (Successor of Aveva Software Private Limited), Mumbai vs. Deputy Commissioner of Income Tax, Circle 15(1)(1), Mumbai

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

ITA 4813/MUM/2024[2020-21]Status: DisposedITAT Mumbai14 Feb 2025AY 2020-21

Bench: Shri Sandeep Singh Karhail, Jm & Shri Girish Agrawal, Am आयकर अपील सं./Ita No.4813/Mum/2024 (िनधा"रण वष" / Assessment Year :2020-2021) Aveva Information Technology Vs. Dcit, Circle-15(1)(1), India Private Limited(Successor Mumbai Of Aveva Software Pvt. Ltd.) Unit No.202, A Wing Supreme Business Park, Hiranandani Gardens, Supreme City Powai Mumbai-400076 "थायी लेखा सं./Pan No. : Aadca 0847 M (अपीलाथ" /Appellant) .. (""यथ" / Respondent) िनधा"रती की ओर से /Assessee By : Mr. Yash Ranglani, Ar राज"व क" ओर से /Revenue By : Shri Kiran Unavekar, Sr.Dr सुनवाई क" तारीख / Date Of Hearing : 12/02/2025 घोषणा क" तारीख/Date Of Pronouncement : 14/02/2025 आदेश / O R D E R Per Sandeep Singh Karhail, Jm : The Assessee Has Filed The Present Appeal Challenging The Impugned Final Assessment Order Dated 30.07.2024, Passed Under Section 143(3) R.W. Section 144C(13) R.W. Section 144B Of The Income Tax Act, 1961 (“The Act”) Pursuant To The Directions Issued By The Learned Dispute Resolution Panel-1, Mumbai-2, For The Assessment Year 2020-21. 2. At The Time Of The Hearing, The Learned Ar For The Assessee Submitted A Copy Of The Acknowledgement Dated 31.01.2025 Of Filing Of Form 1 Under Direct Tax Vivad Se Vishwas Scheme, 2024 & Stated That 2 Aveva Information Technology India Pvt. Ltd. The Assessee Has Opted For Direct Tax Vivad Se Vishwas Scheme, 2024.In Light Of The Above Letter, We Dismiss The Appeal Of The Assessee With The Liberty To Reinstate The Appeal If Its Application Under Direct Tax Vivad Se Vishwas Scheme, 2024, Is Not Accepted.

For Appellant: Mr. Yash Ranglani, ARFor Respondent: Shri Kiran Unavekar, Sr.DR

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

section 144C(13) r.w. section 144B of the Income Tax Act, 1961 (“the Act”) pursuant to the directions issued by the learned Dispute Resolution Panel-1, Mumbai-2, for the assessment year 2020-21. 2. At the time of the hearing, the learned AR for the assessee submitted a copy

DCIT, New Delhi vs. M/S. Rhc Holding Pvt. Ltd., New Delhi

In the result, appeal of the assessee is allowed

ITA 2446/DEL/2014[2009-10]Status: DisposedITAT Delhi14 Feb 2025AY 2009-10

Bench: Shri Vikas Awasthy& Shri Brajesh Kumar Singhआअसं.2446/िद"ी/2024(िन.व. 2017-18) Gsma Ltd., 1000 Abernathy Road, Suite 450, Atalanta, Untied State Of America ...... अपीलाथ"/Appellant Pan: Aaecg-1610-K बनाम Vs. Assistant Commissioner Of Income-Tax, International Taxation 1(3)(1), Civic Centre, ....."ितवादी/Respondent Minto Road, New Delhi 110002 अपीलाथ" "ारा/ Appellant By: Shri P.P Singh, Advocate "ितवादी"ारा/Respondent By: Shri M.S Nethrapal, Cit-Dr सुनवाई क" ितिथ/ Date Of Hearing : 06/08/2025 घोषणा क" ितिथ/ Date Of Pronouncement : 04/11/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Assessment Order Dated 06.04.2021 Passed U/S. 143(3) R.W.S 144C(13) Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’), For Assessment Year 2017-18. 2. The Registry Has Issued Defect Memo Stating That The Appeal Is Time Barred By 1076 Days. The Assessee Has Filed An Application Supported By An Affidavit Citing Reasons For Delay In Filing Of Appeal.

For Appellant: Shri P.P Singh, AdvocateFor Respondent: Shri M.S Nethrapal, CIT-DR

Section 143(3)Section 9(1)(vii)

assessee @70% of the service fee received by MSAI from the third party i.e. Mobile Equipment Manufactures. The Assessing Officer (AO) and the Dispute Resolution Panel (DRP) held that the Administration Fee received by the assessee is in the nature of royalty as per Section

Agrawal Distilleries Pvt Ltd, Indore vs. Commissioner of Income Tax (Appeals), Delhi

In the result, appeal of the assessee Ground Nos 9 & 10 is allowed

ITA 1169/MUM/2024[2014-2015 (Q3)]Status: DisposedITAT Mumbai12 Feb 2025

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Percy J. Pardiwalla/wShriFor Respondent: Ms. Vatsala Jha(PCIT)

Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 35ASection 36(1)(m)Section 37(1)Section 40Section 43(1)

following grounds of appeal: - “The Appellant respectfully submits that: On the facts and circumstances of the case and in law, the learned Dispute Resolution Panel -11. New Delhi (DRP") has erred in passing the order under section 144C(5) of the Income Tax Act, 1961 (Act"), partly confirming the adjustments ... Assessing Officer[‘the AO’] u/s 143(3) r.w.s. 144C(1) of the Act. 30" April 2013 | Objections filed by the Appellant before the Dispute Resolution Panel [‘DRP’] 18"December Directions issued by the DRP u/s 144C(5) of the Act. 2013 30" January Final Assessment Order passed

Vodafone Digilink Ltd., New Delhi vs. DCIT, New Delhi

In the result, appeal of the assessee Ground Nos 9 & 10 is allowed

ITA 1169/DEL/2014[2009-10]Status: DisposedITAT Mumbai12 Feb 2025AY 2009-10

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Percy J. Pardiwalla/wShriFor Respondent: Ms. Vatsala Jha (PCIT)

Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 35ASection 36(1)(m)Section 37(1)Section 40Section 43(1)

following grounds of appeal: - “The Appellant respectfully submits that: On the facts and circumstances of the case and in law, the learned Dispute Resolution Panel -11. New Delhi (DRP") has erred in passing the order under section 144C(5) of the Income Tax Act, 1961 (Act"), partly confirming the adjustments ... Assessing Officer['the AO'] u/s 143(3) r.w.s.144C(1) of the Act. 30th April 2013 Objections filed by the Appellant before the Dispute Resolution Panel ['DRP'] 18th December 2013 Directions issued by the DRP u/s 144C(5) of the Act. 30th January 2014 Final Assessment Order passed

M/S Gkb Optic Technologies, Pvt. Ltd., Noida vs. ITO., Ward-2(1)(4), Agra

Appeal is dismissed in above terms

ITA 139/AGR/2021[2016-17]Status: DisposedITAT Agra11 Feb 2025AY 2016-17

Bench: : Shri Satbeer Singh Godara & Shri Manoj Kumar Aggarwalassessment Year: 2016-17

against the National e-Assessment Centre, Delhi’s DIN and order no. ITBA/AST/S/143(3)/2020-21/1032092639(1) dated 31.03.2021 framed in consequence to the Dispute Resolution Panel (“DRP”)-2, Delhi’s directions dated 24.12.2020, involving proceedings under sections 143(3) r.w.s. 144C(13), 143(3A) & 143(3B) of the Income

Kreuz Subsea Technologies Pte. Ltd., Mumbai vs. ACIT, Int. Tax. 2(1)(2), Delhi

The Appeal of the Assessee is dismissed

ITA 1767/DEL/2021[2017-18]Status: DisposedITAT Delhi11 Feb 2025AY 2017-18

Bench: Shri Yogesh Kumar U.S. & Shri Brajesh Kumar Singhkreuz Subsea Technologies Pte. Ltd. Srbc & Associates Llp 16Th Floor, The Ruby,29, Senapatibapat Marg, Dadar (West), Mumbai Pan: Aafck7070C Vs. Acit International Taxation, Civic Centre, Minto Road, New Delhi

Section 143(3)Section 144CSection 144C(13)Section 234BSection 234CSection 270A

ACIT On the facts and circumstances of the case and in law, the Assessing Officer, pursuant to directions of Hon'ble Dispute Resolution Panel ('DRP") has: 1. erred in assessing total income at Rs.6,66,77,861 as against Rs.7,18,313 returned by the Appellant. 2. erred in passing

M/S. Global Offshore Services Ltd, Mumbai vs. Dy. Commissioner of Income Tax 5(1)(1), Mumbai

ITA 5479/MUM/2024[2021-22]Status: DisposedITAT Mumbai10 Feb 2025AY 2021-22

Bench: Shri Sandeep Gosain (Jm) & Shri Omkareshwar Chidara (Am) Global Offshore Services Dcit 5(1)(1) Ltd. Room No. 525 3Rd Floor, Prospect Vs. Aayakar Bhavan Chambers, D.N. Road M.K. Road Fort, Mumbai-400 001. Mumbai-400020. Pan : Aaacg2204K Appellant Respondent

For Appellant: Shri Akhtar HussainFor Respondent: Shri Nitesh Joshi

Section 143(1)Section 270A(1)

appellant in the above captioned appeal :- 1. That on the facts and the circumstances of the case and in law, the Assessing Officer & Dispute Resolution Panel [hereinafter referred to as 'AO/DRP'] has erred in proposing to determine Arm's Length Price with respect to corporate guarantee given to bank

Solvay Specialities India Private Limited, Mumbai vs. The Assistant Commissioner of Income Tax, Circle 16(2) / Assessment Unit, NFAC, Mumbai

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

ITA 6686/MUM/2024[2021-22]Status: DisposedITAT Mumbai07 Feb 2025AY 2021-22

Bench: MS. KAVITHA RAJAGOPAL (Judicial Member), SHRI. GIRISH AGARWAL (Accountant Member)

For Appellant: Shri. DhavalFor Respondent: Shri. Pravin Salunkhe, Sr. DR

Section 143(3)Section 153Section 92CSection 92C(3)

r.w.s. 144C(13) r.w.s. 144B of the Income Tax Act, 1961 (‘the Act'), pursuant to the directions of Hon’ble Dispute Resolution Panel (‘Hon’ble DRP’ for short), pertaining to the Assessment Year (‘A.Y.’ for short) 2021-22. 2. The assessee has raised the following grounds of appeal ... legal considerations, the Appellant contends that the Learned Assessing Officer (AO) and Transfer Pricing Officer (TPO) have erred, and the Hon’ble Dispute Resolution Panel (DRP) further erred in: 1.1. On the facts and circumstances of the case and in law, the Learned Assessing Officer (AO) / Transfer Pricing Officer

Techint India Private Limited, Mumbai vs. ITO, Mumbai

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

ITA 6656/MUM/2024[2021-22]Status: DisposedITAT Mumbai07 Feb 2025AY 2021-22

Bench: Ms. Kavitha Rajagopal, Jm & Shri. Girish Agarwal, Am Techint India Private Limited Assessment Unit, Income Tax A/5Th Floor, I Think Techno Campus, Department Pokhran Road No. 2, Off Eastern Jurisdictional Ao, Income Tax Express Highway, Thane West, Vs. Department, Jurisdictional Ao, Mumbai – 400601. Qureshi Mansion, Gokhale Road, Thane. Pan/Gir No. Aadct3127D (Assessee) : (Respondent) Assessee By : Shri. Kaustubh Karkhania Respondent By : Shri. Pravin Salunkhe, Sr. Dr Date Of Hearing : 06.02.2025 Date Of Pronouncement : 07.02.2025 O R D E R Per Kavitha Rajagopal, J M: This Appeal Has Been Filed By The Assessee, Challenging The Assessment Order Dated 25.10.2024 Passed By The Learned Assessing Officer (‘Ld. Ao’ For Short) U/S. 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income Tax Act, 1961 (‘The Act'), Pursuant To The Directions Of Hon’Ble Dispute Resolution Panel (‘Hon’Ble Drp’ For Short), Pertaining To The Assessment Year (‘A.Y.’ For Short) 2021-22. 2. The Assessee Filed Applications Dated 13.01.2025 & 03.02.2025 Stating That The Assessee Has Opted To Settle The Dispute Through The Direct Tax Vivad Se Vishwas Scheme, 2024 Along With Copy Of Form 1, Form 2 & Form 3 Dtvsv 2024. Techint India Private Limited 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 07.02.2025 (Girish Agarwal)Mumbai; Dated: 07.02.2025 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: Shri. Kaustubh KarkhaniaFor Respondent: Shri. Pravin Salunkhe, Sr. DR

Section 143(3)

Hemant Kumar, Haryana vs. ITO, Ward- 1(3), Gurgaon

In the result, this issue is decided in favour of the assessee/appellant and against the Department

ITA 1465/DEL/2019[2011-12]Status: DisposedITAT Delhi07 Feb 2025AY 2011-12

Bench: SHRI CHALLA NAGENDRA PRASAD, JUDICIAL MEMBER, SHRI NAVEEN CHANDRA (Accountant Member)

Counsel submits that though the assessee has raised other issues viz. tenability of the impugned final assessment order and directions of the Dispute Resolution Panel (DRP) beyond jurisdiction in ground no. 2 and 4 of appeal, respectively, the assessee is not pressing said grounds. 3. Per contra, M.S Nethrapal representing

Ivy Comptech Private Limited, Hyderabad vs. DCIT., Circle 2(1), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 908/HYD/2024[2020-21]Status: DisposedITAT Hyderabad04 Feb 2025AY 2020-21

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year: 2020-21 Ivy Competech Private Limited, Vs. The Deputy Commissioner Of Income Tax, Hyderabad. Circle 2(1), Hyderabad. Pan : Aaac18884K. (Appellant) (Respondent) Assessee By: Shri Nageswara Rao, Advocate. Revenue By: Ms. M. Narmada, Cit-Dr Date Of Hearing: 20.01.2025 (Hybrid Hearing) Date Of Pronouncement: 04.02.2025

For Appellant: Shri Nageswara Rao, AdvocateFor Respondent: Ms. M. Narmada, CIT-DR

Section 143(2)Section 143(3)Section 144BSection 144CSection 144C(13)Section 144C(5)Section 92C

r.w.s. 1448 of the Act dated 22.09.2023, was duly served to assessee. 2.1 The assessee filed objections against the assessment order before the Dispute Resolution Panel, which issued directions on 22.05.2024, as per the provisions of section 144C(5) of the Act. In paragraphs 2.4.2 and 2.5.3 of its order ... Income Tax Act and Section 13 of the I.T. Act which reads thus: "Section 144C: Reference to dispute resolution panel:- (1) to (12)... (13) Upon receipt of the directions issued under sub-section (5), the Assessing Officer shall, in conformity with the directions, complete, notwithstanding anything to the contrary contained