“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

Ernst and Young U.S. LLP, United States vs. ACIT, Circle International Tax 1(2)(2), New Delhi

In the result, the appeal of the assessee is allowed

ITA 3253/DEL/2023[2021-22]Status: DisposedITAT Delhi07 Aug 2024AY 2021-22

Bench: Dr. B. R. R. Kumar, Ms. Madhumita Roy

For Appellant: Sh. S. Ganesh, Sr. Adv. &For Respondent: Sh. Vivek Vardhan, Sr. DR

Section 143(3)Section 144CSection 192

Assistant Commissioner of Income Tax, Circle International Tax 1 (2)(2), Delhi (“Ld. AO”) in conjunction with the directions passed by the Ld. Dispute Resolution Panel (“Ld. DRP”) in the case of Appellant for AY 2021-22, assessing the income of the Appellant for the relevant assessment year

Nord Anglia Education Limited, United Kingdom vs. DCIT Intl. Taxation Circle 2(2)(2), New Delhi

In the result, the appeal of the assessee is allowed

ITA 2385/DEL/2023[2020-21]Status: DisposedITAT Delhi07 Aug 2024AY 2020-21

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

For Appellant: Sh. Kanchan Kaushal, AdvFor Respondent: Sh. Vijay B. Vasanta, CIT-DR

Section 143(3)Section 144CSection 270A

Learned Deputy Commissioner of Income tax, Circle 1(1)(1), International Taxation, Delhi ('Ld. AO') pursuant to the directions of the Ld. Dispute Resolution Panel-2, New Delhi (Ld. DRP') making an addition of INR 28,64,22,509 is bad in law and therefore, liable to be set aside ... Additionally, the Assessee filed an application for additional evidence in accordance with Rule 4(3) read with Rule 9 of the Income tax (Dispute Resolution Panel) Rules, 2009 (’DRP Rules’) before the ld. DRP, in order to substantiate that the centralized administrative services/ support services regarding educational quality improvement, financial

Assotech Moonshine Urban Developers Private Ltd., Delhi vs. Dc/ACIT Tp 1(1)(1), Delhi

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

ITA 1037/DEL/2022[2018-19]Status: DisposedITAT Delhi07 Aug 2024AY 2018-19

Bench: Shri Pradip Kumar Kedia & Shri Narinder Kumar

For Appellant: Shri Mansi Jain, Chartered AccountantFor Respondent: Shri Rajesh Kumar, CIT-DR

Section 143(3)Section 144CSection 144C(5)Section 92D

When the matter was called for hearing, the ld. counsel for the assessee straightaway adverted to paragraph 3.3.2 of the directions of the Dispute Resolution Panel dated 09.02.2022 passed under I.T.A. No.1037/Del/2022 2 Section 144C(5) of the Act and submitted that as per the DRP directions

Emerging Markets Index Non Lendable Fund, Mumbai vs. DCIT (International Taxation)-2(2)(1), Mumbai

In the result appeal of the assessee is partly allowed

ITA 4589/MUM/2023[2021-22]Status: DisposedITAT Mumbai05 Aug 2024AY 2021-22

Bench: Shri Prashant Maharishi, Am & Shrisandeep Singh Karhail, Jm A.Y.2021 – 22 Emerging Markets Index The Deputy Commissioner Of Non-Lendable Fund Income Tax (International C/O Ernst & Young Llp Taxation) – Circle –2 (2) (1) 17Th Floor 1722, 17T H Floor, Vs. The Ruby Air India Building, 29, Senapati Bapat Marg Nariman Point, Dadar (West) Mumbai – 21 Mumbai – 28 (Appellant) (Respondent) Pan Aaaae3262D Assessee By Shri Anish Thacker & Pranay Gandhi Revenue By Shri Anil Sant Additional Commissioner Of Income Tax Date Of Hearing 7 May 2024 Date Of Pronouncement 5 August 2024

Section 111ASection 115ASection 234ASection 234BSection 234CSection 270A

total income of Rs. 923,071,640/– was assessed at Rs. 992,154,207/–, passed in pursuance of direction of The Dispute Resolution Panel – 1, Mumbai (the learned DRP) dated 12/9/2023. ITA No.4589/M UM/2023 A Y 2021 – 22 Emerging markets index non-lendable fund versus Deputy Commissioner of income ... notices were issued, and consequently draft order of assessment was passed on 19/12/2022 against which the assessee filed an objection before the learned dispute resolution panel who passed a direction on 12/9/2023 which resulted into the assessment order dated 15/10/2023. 4. The brief controversy involved in this appeal is that

Aban Offshore Limited, Chennai vs. DCIT, Corp Circle 1(1), Chennai

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

ITA 556/CHNY/2024[2014-15]Status: DisposedITAT Chennai31 Jul 2024AY 2014-15

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 556/Chny/2024 िनधा"रणवष" / Assessment Year: 2014-15 Deputy Commissioner Of Income Aban Offshore Limited, V. Tax, 113, Janpriya Crest, Corporate Circle -1(1), Pantheon Road, Egmore, Chennai. Tamilnadu – 600 008. [Pan:Aaaca-3012-H] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. P. Murali Mohan Rao, Ca (Virtual) ""यथ"क"ओरसे/Respondent By : Shri. Nanda Kumar, Cit सुनवाई क" तारीख/Date Of Hearing : 05.06.2024 घोषणा क" तारीख/Date Of Pronouncement : 31.07.2024 आदेश /O R D E R

For Appellant: Shri. P. Murali Mohan Rao, CA (Virtual)For Respondent: Shri. Nanda Kumar, CIT

Section 115JSection 143(3)Section 154Section 35DSection 90Section 92C

been caused to the income or loss as returned by the assessee during the year under consideration not. The scope of Reference to Dispute Resolution Panel is as per sub sec.2 of sec. 144C of the Act i.e. the assessee can file his objections only in relation to such variation

Western Digital Technologies Inc., United States of America vs. Deputy Commissioner of Income-Tax, (International Taxation), Circle-2(1), Bangalore

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

ITA 343/BANG/2024[2016-17]Status: DisposedITAT Bangalore31 Jul 2024AY 2016-17

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

For Appellant: Shri Ajay Rotti, CAFor Respondent: Shri Sunil Kumar Agarwal

Section 234ASection 234BSection 271(1)(c)

grounds stated hereunder are independent of and without prejudice to one another. The Appellant submits as under: 1. Directions of the Hon'ble Dispute Resolution Panel are bad in law and liable to be quashed 1.1. The Hon'ble Dispute Resolution Panel (`the Hon'ble Panel') has erred in incorrectly

Huntsman Investments (Netherlands), Mumbai vs. The Dy Commissioner of Income Tax International Tax Circle-2(2)(2), Mumbai

ITA 4222/MUM/2023[2021-22]Status: DisposedITAT Mumbai31 Jul 2024AY 2021-22

Bench: Shri Anikesh Banerjee & Miss. Padmavathy S.

Section 143(3)Section 144C(13)Section 144C(5)Section 234ASection 234B

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “I”, MUMBAI BEFORE SHRI ANIKESH BANERJEE, JUDICIAL MEMBER AND MISS. PADMAVATHY S

Mildred Ponnoth, Mumbai vs. Income Tax Officer (International Tax)-3(3)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 1802/MUM/2024[2016-17]Status: DisposedITAT Mumbai30 Jul 2024AY 2016-17

Bench: MS.KAVITHA RAJAGOPAL (Judicial Member), SMT RENU JAUHRI (Accountant Member)

Section 143(1)Section 144Section 144C(5)Section 147Section 148Section 148ASection 234A

r.w.s. 144C(13) of the Income Tax Act, 1961 (‘the Act’) for Assessment Years 2016-17; pursuant to the directions issued by Dispute Resolution Panel, Mumbai (‘DRP’). 2. The grounds of appeal raised by the assessee read as under:- 2 Mrs. Mildred Ponnoth Ground No.1 Section 147/148A/148 Issue. Validity ... erred in adding Rs 10,36,000/- as income and raising tax/interest demand of Rs 4,00,502/- 2.2 The learned AO and Dispute Resolution Panel grossly erred in not considering hardship allowance as capital receipt as held in judicial authorities of Hon'ble Income Tax Appellate Tribunal, Mumbai

Benu Networks Packet Switch Private Limited, Hyderabad vs. ACIT Circle-1(2), Hyderabad

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

ITA 194/HYD/2021[2016-17]Status: DisposedITAT Hyderabad29 Jul 2024AY 2016-17

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year: 2016-17 M/S. Benu Networks Packet Vs. The Acit, Circle – 1(2), Switch Private Limited, Hyderabad. Hyderabad. Pan : Aaecb4902B (Appellant) (Respondent) Assessee By: Shri Ashish Jain, Ca & Ms. M. Sripada, Ca. Revenue By: Ms. Th A Vijaya Lakshmi, Cit-Dr 20.06.2024 Date Of Hearing: Date Of Pronouncement: 29.07.2024

For Appellant: Shri Ashish Jain, CA and Ms. M. Sripada, CAFor Respondent: Ms. TH a Vijaya Lakshmi, CIT-DR

Section 142(1)Section 143(2)Section 143(3)Section 92BSection 92C

passed the draft assessment order on 30.10.2019 u/s 92CA(3) of the Act. Aggrieved such draft assessment order, assessee preferred objections before the Dispute Resolution Panel (DRP) and pursuant to the directions of the DRP dt. 16.02.2021, Assessing 5 Officer finalized the assessment, by making addition of TP adjustment

ACIT, Air India Building, Nariman Point, Mumbai vs. De Beers Uk Limited, Mumbai

In the result, the appeal of the learned assessing officer is dismissed

ITA 2466/MUM/2024[2014-15]Status: DisposedITAT Mumbai29 Jul 2024AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shri Sunil Kumar Singh, Jm The Assistant Commissioner Of Vs. De Beers U K Limited Income Tax ( International C/O S R Batliboi & Co Taxation 2(1) (1) Mumbai 14Th Floor 17Th Floor Air India Building The Ruby Nariman Point 29, Senapati Bapatmarg Mumbai Dadar W Mumbai (Appellant) (Respondent) Pan No. Aacct5530B

For Appellant: Shri Pranay GandhiFor Respondent: Shri Anil Sant , SR DR

Section 143Section 144C

basis of these services the learned assessing officer held that the services provided are value-added services provided in earlier years. The dispute resolution panel for assessment year 2007 – 08, 2008 – 09 and 2009 – 10 has upheld treatment of value-added services as fees for technical services and taxed them ... with section 144C was also passed on 14/2/2017 as the assessee submitted that it is opting not to file its objections before the dispute resolution panel. Thus, the draft order was finalized on a similar line. ITA number 2466/M/2024 A.Y. 2014-15 The ACIT Int tax 2 (1) (1) , Mumbai

Tech Data (Singapore) Pte Limited, Mumbai vs. DCIT, International Taxation Circle-4(1)(2), Mumbai

In the result, ground No.3 of appeal is allowed

ITA 4540/MUM/2023[2021-22]Status: DisposedITAT Mumbai29 Jul 2024AY 2021-22

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Rahul Chaudhary, Hon’Ble

For Appellant: Shri Nitesh Joshi, A/RFor Respondent: Shri Anil Sant, Addl. CIT D/R

Section 143(3)Section 144C(13)Section 234ASection 234BSection 253(1)(d)Section 270ASection 274

read with section 144C(13) of the Act in pursuance of the directions dated 22 September 2023 issued by the Honorable Dispute Resolution Panel (hereinafter referred to as 'DRP'), on the following ground, which are independent of and without prejudice to each other: I.T.A. No. 4540/Mum/2023 2 1. Ground

Visteon Corporation, Michigan vs. DCIT, Intenl Taxn, Circle-2(2), Chennai

In the result, the appeals filed by the assessee in ITA Nos

ITA 262/CHNY/2023[2017-18]Status: DisposedITAT Chennai26 Jul 2024AY 2017-18

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita Nos.:259, 260, 261 & 262/Chny/2023 िनधा"रण वष"/Assessment Years:2014-15, 2015-16, 2016-17 & 2017-18 & S.A. Nos. 28, 29 & 30/Chny/2023 [In Ita Nos. 259, 261 & 262/Chny/2023] M/S. Visteon Corporation, The Deputy Commissioner Grace Lake Corporation Centre, Vs. Of Income Tax, Van Buren Township, International Taxation, Michigan - 48111 Circle 2(2), Chennai. Pan: Aadcv 5660K (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Ajay Vohra, Sr. Advocate (By Virtual) Shri Aditya Vohra, Advocate ""यथ" क" ओर से/Respondent By : Shri Nilay Bara Som, Cit सुनवाई क" तारीख/Date Of Hearing : 01.07.2024 घोषणा क" तारीख/Date Of Pronouncement : 26.07.2024 आदेश /O R D E R Per Mahavir Singh: These Three Appeals By The Assessee In Ita Nos.259, 261 & 262/Chny/2023 Are Arising Out Of The Final Assessment Orders Passed By The Assistant Commissioner Of Income Tax, International Taxation Circle 2(2), Chennai Vide Orders Of Even Date 06.01.2023 In Pursuant To The Directions Of The Dispute Resolution Panel-2

For Appellant: Shri Ajay Vohra, Sr. Advocate (By Virtual)For Respondent: Shri Nilay Bara Som, CIT

Section 142(1)Section 263

Commissioner of Income Tax, International Taxation Circle 2(2), Chennai vide orders of even date 06.01.2023 in pursuant to the directions of the Dispute Resolution Panel-2, ITA Nos. 259 to 262/CHNY/2023 & SA Nos.28 to 30/CHNY/2023 Bengaluru vide directions of even date 19.12.2022 for the assessment years

Visteon Corporation, Michigan vs. DCIT, Intenl Taxn, Circle-2(2), Chennai

In the result, the appeals filed by the assessee in ITA Nos

ITA 261/CHNY/2023[2016-17]Status: DisposedITAT Chennai26 Jul 2024AY 2016-17

For Appellant: Shri Ajay Vohra, Sr. Advocate (By Virtual)For Respondent: Shri Nilay Bara Som, CIT

Section 142(1)Section 263

Visteon Corporation, Michigan vs. DCIT International Taxation, Circle 2(2), Chennai

In the result, the appeals filed by the assessee in ITA Nos

ITA 260/CHNY/2023[2015-16]Status: DisposedITAT Chennai26 Jul 2024AY 2015-16

For Appellant: Shri Ajay Vohra, Sr. Advocate (By Virtual)For Respondent: Shri Nilay Bara Som, CIT

Section 142(1)Section 263

Visteon Corporation, Michigan vs. DCIT, Intenl Taxn, Circle-2(2), Chennai

In the result, the appeals filed by the assessee in ITA Nos

ITA 259/CHNY/2023[2014-15]Status: DisposedITAT Chennai26 Jul 2024AY 2014-15

For Appellant: Shri Ajay Vohra, Sr. Advocate (By Virtual)For Respondent: Shri Nilay Bara Som, CIT

Section 142(1)Section 263

Sundaram Fasteners Limited, Chennai vs. DCIT Corporate Circle 6(2), Chennai

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

ITA 3236/CHNY/2017[2013-14]Status: DisposedITAT Chennai26 Jul 2024AY 2013-14

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.3236/Chny/2017 िनधा"रण वष"/Assessment Year: 2013-14 V. M/S.Sundram Fasteners Ltd., The Dcit, 98-A, 7Th Floor, Corporate Circle-6(2), Dr.Radhakrishnan Salai, Chennai. Mylapore, Chennai-600 004. [Pan: Aaacs 8779 D] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Vikaram VijayaraghavanFor Respondent: Shri A. Sasikumar, CIT

assessee against the impugned order of the Assessing Officer (hereinafter in short ‘the AO’) dated 30.10.2017, pursuant to the direction of the Dispute Resolution Panel (hereinafter in short ‘the DRP’) dated 21.09.2017 and pertains to Assessment Year (hereinafter in short ‘AY’) 2013-14. M/s.Sundram Fasteners Ltd. :: 2 :: 2. Ground Nos.2 ... software development and maintenance charges. The annual maintenance charges and cost of upgradation charges are held to be revenue in nature by the Dispute Resolution Panel and it has to be allowed in the year in which it was incurred. In respect of software licenses, the DRP found that there

Bhs India Holdings, Inc., New Jersey, Usa vs. Assistant Commissioner of Income Tax, Circle International Taxation 1(1)(2), Delhi

The appeal is allowed and the stay application which is tagged along is dismissed being infructous

ITA 3286/DEL/2023[2021-22]Status: DisposedITAT Delhi26 Jul 2024AY 2021-22

Bench: Shri Gs Pannu & Shri Anubhav Sharma

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Vizay B. Vasanta, CIT( DR)

Section 143(3)Section 144G(13)

read with section 144C(13) of the Income-tax Act, 1961 ('the Act') pursuant to the directions issued by the Hon'ble Dispute Resolution Panel, Delhi ('DRP or the Panel') is erroneous, bad in law, prejudicial to the Appellant and contrary to the facts and circumstances of the case ... created a new case beyond the direction of the DRP as follows. “10. The Assessing officer has been directed by the Hon'ble Dispute Resolution Panel to verify the factual contentions of the assessee as regards tax residency of the assessee on the basis of TRC filed and its claims

Ncr Global Solutions Limited, Ireland vs. Deputy Commissioner of Income-Tax, Circle 2(2)(2), International Tax, New Delhi

In the result, the grounds are sustained and the appeal filed by the Assessee is allowed

ITA 3230/DEL/2023[2021-22]Status: DisposedITAT Delhi26 Jul 2024AY 2021-22

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaassessment Year: 2021-22 Ncr Global Solutions Limited, Vs Dcit, Lakeview Drive, Circle 2(2)(2), Airside Business Park, International Taxation, Swords, Co. Dublin, K67 N2N9, New Delhi. Ireland. Pan: Aadcn5762E (Appellant) (Respondent) Assessee By : Shri Nageshwar Rao & Ms Viyushti Rawat, Advocate Revenue By : Shri Vizay B. Vasanta, Cit-Dr Date Of Hearing : 25.07.2024 Date Of Pronouncement : 26.07.2024 Order Per Anubhav Sharma, Jm: This Appeal Is Preferred By The Assessee Against The Order Dated 09.08.2023 Of The Dispute Resolution Panel-2, New Delhi (Hereinafter Referred To As ‘The Ld. Drp’) In Objection No.220 Dated 20.01.2023 Arising Out Of The Objection Before It Against The Order Passed U/S 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’), By The Dcit, Circle International Taxation 2(2)(2), New Delhi (Hereinafter Referred To As The Ld. Ao).

For Appellant: Shri Nageshwar Rao &For Respondent: Shri Vizay B. Vasanta, CIT-DR

Section 142(1)Section 143(3)

Date of Pronouncement : 26.07.2024 ORDER PER ANUBHAV SHARMA, JM: This appeal is preferred by the assessee against the order dated 09.08.2023 of the Dispute Resolution Panel-2, New Delhi (hereinafter referred to as ‘the Ld. DRP’) in Objection No.220 dated 20.01.2023 arising out of the objection before it against ... International Tax, New Delhi (“AO”) in pursuance of the Directions dated 09 August 2023 issued under Section 144C(5) by Hon'ble Dispute Resolution Panel -2 (“DRP”), New Delhi, on the following grounds which are without prejudice to each other: 1. Directions issued by DRP under section 144C

R1 Rcm Holdco Inc. (Formerly Known As R1 Rcm Inc.), Usa vs. DCIT, Int. Taxation, Gurgaon

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

ITA 2044/DEL/2023[2020-21]Status: DisposedITAT Delhi26 Jul 2024AY 2020-21

Bench: SHRI G.S. PANNU, HON'BLE (Vice President), SHRI ANUBHAV SHARMA (Judicial Member)

For Appellant: Shri S.K. Aggarwal, CAFor Respondent: Shri Vijay B. Vasanta, CIT-DR

Section 143(3)Section 9(1)(vi)Section 92C

assessment order under Section 143(3) read with Section 1440(13) of the Income-tax Act, 1961 (‘the Act’), and the Hon’ble Dispute Resolution Panel (‘DRP’), New Delhi has erred in confirming the assessment order, which is wrong and bad in law. The impugned assessment order has been passed

Goodyear India Ltd., Faridabad vs. DCIT, Circle-10(1), New Delhi

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

ITA 346/DEL/2022[2017-18]Status: DisposedITAT Delhi26 Jul 2024AY 2017-18

Bench: Shri G. S. Pannu & Shri Yogesh Kumar U.S.

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Vivek Verma CIT (DR ) and Sh. Kanv Bali, Sr. DR

Section 143(3)Section 144BSection 144CSection 92B

346/DEL/2022 (A.Y 2017-18) 1. That the impugned order of assessment framed by the assessing officer in pursuance of the directions of the Dispute Resolution Panel (hereinafter referred to as ‘DRP’) under Section 143(3) read with Section 144C of the Income ... appellant with its associated enterprises, on the basis of order passed by the Transfer Pricing Officer (‘TPO’) and sustained by the Dispute Resolution Panel (‘DRP’). 2. That the DRP/ TPO erred on facts and in law in making an addition of Rs. 10,38,00,000/-allegedly on account