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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

Turner Broadcasting System Asia Pacific, Inc., United States of America vs. Deputy Commissioner of Income Tax, New Delhi

In the result, Appeal in ITA No

ITA 2432/DEL/2023[2020-21]Status: DisposedITAT Delhi09 Sept 2024AY 2020-21

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.I.T.A. No. 2432/Del/2023 (A.Y 2020-21)

For Appellant: Sh. Manuj Sabharwal, Adv & ShFor Respondent: Sh. Vijay B Vasanta, CIT DR
Section 143(3)Section 9(1)(vi)

that attribution of 10% of advertisement revenues received by TBSAP has been accepted by the Hon'ble Delhi Bench of ITAT. Hon'ble Dispute Resolution Panel as well as the L.d. AO in the Appellant's own case for AY 2007-08 to AY 2017-18, facts of which ... TBSAP from WMIPL are attributable to the alleged Permanent Establishment (‘PE’) of TBSAP in India. 3.4. The assessee filed objections before the Dispute Resolution Panel (‘DRP’) and the DRP directed the A.O. to examine the order of the Tribunal in Assessee’s own case for Assessment Year

Comparex India P.Ltd, New Delhi vs. ITO, Circle-4(2), New Delhi

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

ITA 2151/DEL/2022[2018-19]Status: DisposedITAT Delhi09 Sept 2024AY 2018-19

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Accountant Member)

For Appellant: Shri Ajit Jain, ARFor Respondent: Shri Rajesh Kumar, CIT DR
Section 143(2)Section 143(3)Section 144C(10)Section 144C(13)Section 144C(8)Section 92CSection 92C(3)

passed u/s 143(3) r.w.s.144C (13) of the Income Tax Act, 1961 (hereinafter called ‘the Act’) subsequent to the direction of the Ld. Dispute Resolution Panel (DRP)/TPO vide order dated 03.06.2022 for Assessment Year 2018-19. 2. Brief facts of the case are, assessee filed its return of income ... Delhi dated 15.09.2021 and the income was assessed with TP adjustments proposed by the TPO. 3. Aggrieved, assessee filed objections before the ld. Dispute Resolution Panel (DRP) and made detailed submissions before the ld. DRP. Ld. DRP passed the order dated03.06.2022 with the directions to Assessing Officer/TPO. Subsequently, final assessment

Ebro India Pvt.Ltd., Delhi vs. ACIT Circle-7(1), Delhi

In the result, the ground no 4 raised by the assessee is allowed

ITA 1291/DEL/2022[2018-19]Status: HeardITAT Delhi09 Sept 2024AY 2018-19

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Accountant Member)

For Appellant: Shri Rohit Jain, AdvocateFor Respondent: Shri Rajesh Kumar, CIT DR
Section 143(3)Section 144BSection 144CSection 68

passed u/s 143(3) r.w.s.144C (13) of the Income Tax Act, 1961 (hereinafter called ‘the Act’) subsequent to the direction of the Ld. Dispute Resolution Panel (DRP)/TPO vide order dated 15/03/2022 for Assessment Year 2018-19. 2 2. Aggrieved of the above order, assessee is in appeal before ... That on the facts and circumstances of the case and in law, the impugned assessment completed in violation of mandatory directions of the Dispute Resolution Panel (DRP) is illegal and bad in law. 3 2.1. That on the facts and circumstances of the case and in law, the impugned assessment

Micro Focus Software Inc., Usa vs. The Deputy Commissioner of Income-Tax, Circle 3(2)(2), International Taxation, Mumbai

In the result, the appeal is allowed

ITA 4768/MUM/2023[2021-22]Status: DisposedITAT Mumbai06 Sept 2024AY 2021-22

Bench: Ms. Kavitha Rajagopal & Smt. Renu Jauhrimicro Focus Software Inc. V/S. Dcit,(International Tax) बनाम (Formerly Known As Novell Circle 3(2)(2), Inc.) 16Th Floor, Air India Laurel, Block D, 65/2, Building, Nariman Point, Bagmane Tech Park, C. V. Mumbai-400021 Raman Nagar, Byrasandra, Bangalore, Karnataka, India- 560093 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aabcn5034F Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Ketan VedFor Respondent: Shri Anil Sant
Section 143(3)Section 144C(5)Section 234ASection 270A

Circle 3(2)(2) International Taxation, Mumbai ('the Learned Assessing Officer' or 'the Learned AO') passed pursuant to the directions of the Learned Dispute Resolution Panel - 3 Mumbai ('the Learned Panel' or 'the Learned DRP') is bad in law and liable to be quashed. 2. Without prejudice to Ground

Shell Information Technologies International Bv, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation)-4(2)(1), Mumba

In the result, the assessee’s appeal is partly allowed

ITA 4711/MUM/2023[2021-22]Status: DisposedITAT Mumbai06 Sept 2024AY 2021-22

Bench: Ms. Kavitha Rajagopal & Smt. Renu Jauhrishell Information V/S. Dcit (International Tax)- Technology International बनाम 4(2)(1), Bv 17Th Floor, Room No. 1708, C/O. Bsr & Co. Llp, Air India Building, 2Nd Floor, Lodha Excelus, Nariman Point, Apollo Mills Compound, Mumbai-400021 N.M. Joshi Marg, Mahalakshmi, Mumbai-400011 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaics9091A Appellant/अपीलाथी .. Respondent/प्रतिवादी

For Appellant: Shri Madhur AgarwalFor Respondent: Smt. Shaileja Rai
Section 143(3)Section 144C(13)Section 144C(5)Section 153Section 2(24)Section 234ASection 234BSection 234C

assessee against the order dated 31.10.2023 of the DCIT (International Tax) 4(2)(1)- Mumbai passed as per the directions of Dispute Resolution Panel, DRP -2, Mumbai u/s. 144C(5) of the Income-tax Act, 1961 [hereinafter referred to as “Act”] for Assessment Year [A.Y.] 2021-22. 2. The assessee

Atomstroyexport C/O Nuclear Power Corporation of India Ltd, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation) Circle-1(1)(2), Mumbai

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

ITA 4662/MUM/2023[2021-22]Status: DisposedITAT Mumbai06 Sept 2024AY 2021-22

Bench: Ms. Kavitha Rajagopal, Jm & Smt. Renu Jauhri, Am Atomstroyexport Dy. Cit(It) C/O. Nuclear Power Corporation Of Circle-1(1)(2), Room No. 517, 5Th Floor, Air India Building, India Ltd. Vs. 16, Centre 1, World Trade Centre, Nariman Point, Mumbai-400 021 Cuffee Parade, Mumbai-400 005 Pan/Gir No. Aafca 3658 N (Assessee) : (Respondent)

For Respondent: Smt. Shailja Rai
Section 143(2)Section 143(3)Section 144C(1)Section 44BSection 9(1)

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 (‘ld. DRP’ for short), pertaining to the Assessment Year (‘A.Y.’ for short) 2021-22. 2. The assessee had challenged the addition of income from

Gemological Institute of America, Inc., United States of America vs. ACIT (Int Tax Circle) - 2(3)(2), Mumbai

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

ITA 4433/MUM/2023[2021-22]Status: DisposedITAT Mumbai06 Sept 2024AY 2021-22

Bench: Ms. Kavitha Rajagopal & Smt. Renu Jauhrigemological Institute Of V/S. Acit (International बनाम America, Inc. Taxation) Circle 5345, The Rober Mouawad 2(3)(2)Mumbai Camplus, Armada Drive, 17Th Floor, Air India Carlsbad, California Zip – Building, Nariman Point, 092008 Mumbai-400021 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aadcg7962K Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri J. D. MistriFor Respondent: Smt. Shaileja Rai
Section 143(3)

passed by the Assistant Commissioner of Income-tax (International Tax) Circle 2(3)(2), Mumbai [AO] in pursuance to the directions of the Dispute Resolution Panel, Mumbai-1 [DRP] dated 26.09.2023 for Assessment Year [A.Y.] 2021-22. A.Y. 2021-22 Gemological Institute of America 2. The assessee has raised following ... grounds of appeal: “1:0 Re.: General: 1:1 The Assessing Officer/ the Dispute Resolution Panel have erred in assessing the total income of the Appellant at Rs. 3,88,18,14,395/- against the returned income of Rs. 3,32,62,29,830/- thereby determining the tax liability

Jagadeesan, Mani vs. Income Tax Officer (Int Tax )- Ward 3(2)(1), Mumbai

ITA 495/MUM/2024[2018-19]Status: DisposedITAT Mumbai02 Sept 2024AY 2018-19

Bench: Ms Kavitha Rajagopal, Jm & Smt. Renu Jauhri, Am Jagadeesan Mani Ito (Int. Tax)-Ward 3(2)(1) Room No. 1627, 16Th Floor, P O Box No. 2606, Ruwi, Ruwi, Ruwi, Ruwi, 112, Oman Vs. Air India Building, Nariman Point, Mumbai-400 021

For Appellant: Shri Dinesh Kukreja/Punit ShahFor Respondent: Shri Anil Sant
Section 144C(1)Section 144C(5)Section 147Section 148ASection 69Section 69A

passed u/s. 147 r.w.s. 144C(13) of the Income Tax Act, 1961 (‘the Act’ for short) in pursuance of the Hon’ble Dispute Resolution Panel ('Hon’ble DRP' for short) directions, pertaining to the Assessment Year (‘A.Y.’ for short) 2018-19. 2. The assessee has challenged the grounds of reopening ... assessee has been non compliant throughout the assessment proceeding. The assessee filed his objection to the proposed variation before the Hon’ble Dispute Resolution Panel (‘Hon’ble DRP’ for short) and the Hon’ble DRP vide order dated 29.12.2023 issued directions u/s. 144C(5) of the Act, rejecting the original

Nokia India Pvt. Ltd., Gurgaon vs. JCIT, Special Range-6, New Delhi

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 7745/DEL/2018[2014-15]Status: DisposedITAT Delhi30 Aug 2024AY 2014-15

Bench: disregarding the ALP determined by the Appellant and proceeded to determine the ALP himself.

Section 143(3)Section 144CSection 92CSection 92C(3)Section 92D

26/10/2018 passed U/s 143(3) r.w.s.144C of the Income Tax Act, 1961 (hereinafter called ‘the Act’) subsequent to the direction of the Ld. Dispute Resolution Panel (DRP)/TPO vide order dated 05/10/2017 for Asst. Year 2014-15. 2. The assessee has raised the following grounds of appeal:- “1. General Grounds ... Delhi (hereinafter referred to as "the Ld. AO") pursuant to the directions of the Hon'ble Nokia India Pvt. Ltd. vs. JCIT Dispute Resolution Panel-1 (hereinafter referred to as "the Hon'ble DRP") under section 143(3) read with section 144C of the Income

DCIT, New Delhi vs. M/S. Sony India Pvt. Ltd., New Delhi

In the result, appeal filed by the assessee is partly allowed as indicated above and appeal filed by the revenue is dismissed

ITA 1166/DEL/2015[2010-11]Status: DisposedITAT Delhi30 Aug 2024AY 2010-11

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

For Appellant: Shri Nageshwar Rao, AdvocateFor Respondent: Shri Rajesh Kumar, CIT DR
Section 143Section 143(2)Section 143(3)Section 92C

passed u/s 143(3) r.w.s.144C of the Income Tax Act, 1961 (hereinafter called ‘the Act’) subsequent to the direction of the Ld. Dispute Resolution Panel (DRP)/TPO vide order dated 27/01/2014 for Assessment Year 2010-11. 2. Both the cross appeals are interconnected having common issues. Hence, both the appeals ... disallowance of proportionate expenses of Rs.10,96,31,427/-. 13. Aggrieved with the above draft assessment order, assessee filed objections before the ld. Dispute Resolution Panel (DRP) and ld. DRP after considering the submissions of the assessee deleted the disallowance out of advertisement and selling expenses and disallowance of excess

Sony India Private Limited, New Delhi vs. Deputy Commissioner of Income-Tax, New Delhi

In the result, appeal filed by the assessee is partly allowed as indicated above and appeal filed by the revenue is dismissed

ITA 1026/DEL/2015[2010-11]Status: DisposedITAT Delhi30 Aug 2024AY 2010-11

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

For Appellant: Shri Nageshwar Rao, AdvocateFor Respondent: Shri Rajesh Kumar, CIT DR
Section 143Section 143(2)Section 143(3)Section 92C

passed u/s 143(3) r.w.s.144C of the Income Tax Act, 1961 (hereinafter called ‘the Act’) subsequent to the direction of the Ld. Dispute Resolution Panel (DRP)/TPO vide order dated 27/01/2014 for Assessment Year 2010-11. 2. Both the cross appeals are interconnected having common issues. Hence, both the appeals ... disallowance of proportionate expenses of Rs.10,96,31,427/-. 13. Aggrieved with the above draft assessment order, assessee filed objections before the ld. Dispute Resolution Panel (DRP) and ld. DRP after considering the submissions of the assessee deleted the disallowance out of advertisement and selling expenses and disallowance of excess

Borgwarner Emissions Systems India Private Limited, New Delhi vs. DCIT, Circle-4(2), Delhi

Appeal is allowed

ITA 2015/DEL/2022[2013-14]Status: DisposedITAT Delhi29 Aug 2024AY 2013-14

Bench: Shri Pradip Kumar Kedia & Shri Narinder Kumar

For Appellant: Shri Rohit Tiwari, AdvocateFor Respondent: Shri Rajesh Kumar, CIT(DR)
Section 143(3)Section 234BSection 271(1)(c)Section 92C

reason? (f) Which of the prescribed methods needed to be applied 2 for determination of arm’s length price? (g) Whether Dispute Resolution Panel conducted proceedings in accordance with law and as per the directions issued by the Co-ordinate Bench of Appellate Tribunal in the first round of litigation ... Income Tax Act, 1961 (hereinafter referred to as “the Act”) was passed on 18.12.2016. In pursuance to the directions issued by Learned Dispute Resolution Panel-1, New Delhi, (hereinafter referred to as DRP-1), on 13.9.2017, assessment order under section 143(3) of the Act was passed. The Appellate Tribunal

Dassault Systemes Simulia Corp, Chennai vs. DCIT (International Tax)-1 (1), Chennai

The appeal stands allowed in terms of our above order

ITA 349/CHNY/2024[2015-16]Status: DisposedITAT Chennai28 Aug 2024AY 2015-16

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.349/Chny/2024 (िनधा"रणवष" / Assessment Year: 2015-2016) Dassault Systemes Simulia Corp, Vs. The Deputy Commissioner Of C/O. Deloitte Haskins & Sells Llp, Income Tax, 7Th Floor, Asv Ramana Towers, International Taxation 1(1) 52,Venkatnarayana Road, Chennai. Chennai 600 017. [Pan: Aadcd 3705D] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. S.P. Chidambaram, Advocate ""यथ" क" ओर से /Respondent By : Shri. Nilay Baran Som, Irs, Cit. सुनवाई क" तार"ख/Date Of Hearing : 27.08.2024 घोषणा क" तार"ख /Date Of Pronouncement : 28.08.2024 आदेश / O R D E R Per Manu Kumar Giri ()

For Appellant: Shri. S.P. Chidambaram, AdvocateFor Respondent: Shri. Nilay Baran Som, IRS, CIT
Section 143(3)Section 144CSection 147Section 148Section 155(14)

Income Tax, International Taxation-1(1), Chennai (AO) u/s 147 r.w.s. 144C(13) of the Act pursuant to the directions of Ld. Dispute Resolution Panel-2, Bengaluru (DRP) u/s 144C of the Act dated 20.11.2023. The substantive grievance of the assessee are denial of Tax Deducted at Source (TDS) credit ... granting the full TDS credit available as per Form 26AS of the appellant. The Appellant filed an application before the Hon’ble Dispute Resolution Panel ("DRP") under section 144C of the Act. The ld.DRP, vide its directions confirmed the draft assessment order dated 12.12.2023. Aggrieved, assessee preferred an appeal before

Rahul Agarwal, Bengaluru vs. Deputy Commissioner of Income Tax, International Taxation, Circle-1(1), Bengaluru

In the result, the appeal of the assessee is allowed as above

ITA 765/BANG/2024[2016-17]Status: DisposedITAT Bangalore28 Aug 2024AY 2016-17

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

For Appellant: Shri Bharadwaj Sheshadri, Advocate &For Respondent: Shri Senthil Kumar N., CIT(DR)(ITAT), Bengaluru
Section 10(35)Section 111ASection 133ASection 143(3)Section 144C(15)(b)Section 147Section 148Section 148A

following grounds:- IT(IT)A No.765/Bang/2024 Page 2 of 11 Sl. Grounds of Appeal Tax Effect No. 1. The impugned directions of the Dispute Resolution Panel 52,19,475 (DRP) and order of the Assessing Officer (AO) are, bad in law, lacking in jurisdiction, violative of the principles of natural

Thermo Fisher Scientific India P. Ltd, Mumbai vs. ITO-15(3)(1), Mumbai

ITA 988/MUM/2021[2016-17]Status: DisposedITAT Mumbai28 Aug 2024AY 2016-17

Bench: Shri Amarjit Singh & Shri Rahul Chaudhary

Section 143(2)Section 144CSection 144C(5)Section 153

assessing officer has passed draft assessment order u/s 144C of the Act on 23.12.2019. 3. The assessee has filed objections before the Dispute Resolution Panel (DRP) against the additions proposed by the assessing officer in the draft assessment order. The DRP issued direction vide order u/s 144C ... limited especially when further proceedings are contemplated under this Act such as passing the draft assessment order and for the remedy before the dispute resolution panel and final assessment order. 5 ITA No.988/Mum/2021 Thermo Fisher Scientific India Private Limited Α.Υ. 2016-17 6. Heard both the sides and perused

Umw Sher (L) Limited, New Delhi vs. ACIT Int.Tax. Circle-3(1)(1), New Delhi

In the result, appeals are allowed, as indicated above

ITA 2348/DEL/2024[2015-16]Status: DisposedITAT Delhi28 Aug 2024AY 2015-16

Bench: Shri Vikas Awasthy & Shri Naveen Chandraआअसं.2346 To 2348/िद"ी/2024 (िन.व. 2013-14 To 2015-16)

For Appellant: Shri Ved Jain, Advocate &For Respondent: Shri Vizay B Vasanta, CIT-DR
Section 115ASection 147Section 148Section 44BSection 5(2)Section 9(1)(vi)

Section 115A of the Act and under the Article 12 of the India- Malaysia DTAA.” 4. The assessee filed objection before the Dispute Resolution Panel (DRP) against the draft assessment order. The DRP vide directions dated 23.02.2024 rejected objections and confirmed the addition made by AO. The AO vide impugned

Umw Sher (L) Limited, New Delhi vs. ACIT, Int. Tax. Circle-3(1)(1), New Delhi

In the result, appeals are allowed, as indicated above

ITA 2347/DEL/2024[2014-15]Status: DisposedITAT Delhi28 Aug 2024AY 2014-15

Bench: Shri Vikas Awasthy & Shri Naveen Chandraआअसं.2346 To 2348/िद"ी/2024 (िन.व. 2013-14 To 2015-16)

For Appellant: Shri Ved Jain, Advocate &For Respondent: Shri Vizay B Vasanta, CIT-DR
Section 115ASection 147Section 148Section 44BSection 5(2)Section 9(1)(vi)

Section 115A of the Act and under the Article 12 of the India- Malaysia DTAA.” 4. The assessee filed objection before the Dispute Resolution Panel (DRP) against the draft assessment order. The DRP vide directions dated 23.02.2024 rejected objections and confirmed the addition made by AO. The AO vide impugned

Umw Sher (L) Limited, New Delhi vs. ACIT, Int. Tax. Circle-3(1)(1), New Delhi

In the result, appeals are allowed, as indicated above

ITA 2346/DEL/2024[2013-14]Status: DisposedITAT Delhi28 Aug 2024AY 2013-14

Bench: Shri Vikas Awasthy & Shri Naveen Chandraआअसं.2346 To 2348/िद"ी/2024 (िन.व. 2013-14 To 2015-16)

For Appellant: Shri Ved Jain, Advocate &For Respondent: Shri Vizay B Vasanta, CIT-DR
Section 115ASection 147Section 148Section 44BSection 5(2)Section 9(1)(vi)

Section 115A of the Act and under the Article 12 of the India- Malaysia DTAA.” 4. The assessee filed objection before the Dispute Resolution Panel (DRP) against the draft assessment order. The DRP vide directions dated 23.02.2024 rejected objections and confirmed the addition made by AO. The AO vide impugned

Universal Tractor Holding Llc, Usa vs. DCIT, International Taxation Circle 3(1)(1), New Delhi

In the result, the appeal of the assessee is dismissed

ITA 2216/DEL/2022[2019-20]Status: HeardITAT Delhi28 Aug 2024AY 2019-20

Bench: Dr. B. R. R. Kumar, Sh. Sudhir Kumar

For Appellant: Sh. Durgesh Shankar, AdvFor Respondent: Ms. Banita Devi Neorem, CIT-DR
Section 143(3)Section 49

said assessment order issued under Ss 143(3) r.w.s 144C(13) as ab initio illegal and void ab initio. 2. The Ld. Dispute Resolution Panel has erred in fact and in law in holding that interest on the damages awarded through the Decree of an Indian Court is subject ... interest awarded by Hon'ble Delhi High Court on decree damages @ 15% as per India-USA DTAA. 3. The Ld. Dispute Resolution Panel has erred in fact and in law in holding that "interest does not partake the character of the principal amount i.e. Arbitration amount as the interest

Shahnaz Khan, Mumbai vs. CIT(Drp-2), M-2, Mumbai

In the result, the appeal is dismissed as not maintainable

ITA 742/MUM/2024[2018-19]Status: DisposedITAT Mumbai27 Aug 2024AY 2018-19

Bench: SHRI PRASHANT MAHARISHI (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

Section 144Section 144C(2)(b)Section 144C(3)(b)Section 144C(4)Section 144C(5)Section 253

SUNIL KUMAR SINGH (J.M): 1. This appeal has been preferred against the order dated 26.12.2023 passed by the Dispute Resolution Panel (DRP) passed u/s. 144C(5) of the Income tax Act, 1961 [hereinafter referred to as "Act"] for the Assessment year [A.Y.] 2018-19, wherein learned panel has treated ... Khan against the draft assessment order dated 30.03.2023 as 'non- est'. 2. Appellant assessee has filed this appeal on the ground that the Dispute Resolution Panel (DRP) has erred in passing the impugned order resulting into the confirmation of final assessment order dated 11.05.2023. 3. In response to the notice