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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

Van Oord Dredging and Marine Contractors Bv, Mumbai vs. Assistant Commissioner of Income Tax, Intl. Tax Circle - 4(3)(1), Mumbai

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

ITA 4533/MUM/2023[2021-22]Status: DisposedITAT Mumbai04 Jun 2024AY 2021-22

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Darshan KoikarFor Respondent: Shri Anil Sant
Section 143(3)Section 144C(13)Section 144C(5)Section 244ASection 270A

section 143(3) r/w section 144C(13) of the Income Tax Act, 1961 ("the Act"), pursuant to the directions issued by the learned Dispute Resolution Panel-2, Mumbai-1, [“learned DRP\ “], under section 144C(5) of the Act, for the assessment year 2021-22. 2. In its appeal, the assessee

Vilas Sampatrao Garud, Yashshree Park vs. Assessment Unit, Income Tax Department, Not Known

In the result, the appeal is dismissed

ITA 966/PUN/2023[2017-18]Status: DisposedITAT Pune03 Jun 2024AY 2017-18

Bench: Shri Inturi Rama Rao & Ms. Astha Chandraआयकर अपील सं. / Ita No.966/Pun/2023 "नधा"रण वष" Assessment Year : 2017-18

For Appellant: Shri Charuhas Dwarkanath UpasaniFor Respondent: Shri Sourabh Nayak
Section 10Section 115VSection 12ASection 132Section 143Section 143(3)Section 144BSection 147Section 153ASection 153C

section (3), of section 143 or section 147 7c[or section 153A or section 153C] in pursuance of the directions of the Dispute Resolution Panel or an order passed under section 154 in respect of such order;] †or [(e) an order passed by an Assessing Officer under sub-section

M/S Kantar Gdc India Pvt. Ltd. (Formerly Tns India Pvt Ltd), Hyderabad vs. Dy. Commissioner of Income Tax, Circle-2(2), Hyderabad

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

ITA 2261/HYD/2017[2013-14]Status: HeardITAT Hyderabad03 Jun 2024AY 2013-14

Bench: Shri Mahavir Singh & Shri Manjunatha, G.आ.अपी.सं /Ita No.2261/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2013-14) M/S. Kantar Gdc India (P) Vs. Dy. C. I. T. Ltd (Formerly Tns India (P) Circle 2(2) Ltd, Hyderabad Hyderabad Pan:Aabcn2278F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate Harpreet Singh Ajmani राज" व "ारा/Revenue By:: Shri Shiva Sewak, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 15/05/2024 घोषणा की तारीख/Pronouncement: 03/06/2024 आदेश/Order

For Appellant: Advocate Harpreet Singh AjmaniFor Respondent: : Shri Shiva Sewak, CIT(DR)
Section 143(3)Section 144C(5)Section 271(1)(c)

order passed by the Assessing Officer u/s 143(3) r.w.s. 144(5) r.w.s. 144(13) of the I.T. Act, 1961 in pursuant to Dispute Resolution Panel-1 direction issued u/s 144C(5) of the I.T. Act, 1961 dated 14.9.2017 and pertains to A.Y 2013-14. Page ... facts and circumstances of the case and in law, the learned Assessing Officer ("AO")/ Learned Transfer Pricing Officer (TPO") and the Hon'ble Dispute Resolution Panel ('DRP') erred in: TRANSFER PRICING MATTERS: ALP for management fees 1. Determining the arm's length price in respect of payment towards management services

Satyam Venture Engineering Services Private Limited, Secunderabad vs. Assistant Commissioner of Income Tax, Central Circle -3(2), Hyderabad

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

ITA 192/HYD/2021[2016-17]Status: DisposedITAT Hyderabad31 May 2024AY 2016-17

Bench: Shri K.Narasimha Chary & Shri Madhusudan Sawdiaआ.अपी.सं / Ita-Tp No. 192/Hyd/2021 (धििाारण वर्ा / Assessment Year: 2016-17) Satyam Venture Assistant Commissioner Engineering Services Vs. Of Income Tax, Private Limited, Central Circle-3(2), Secunderabad Hyderabad [Pan No. Aafcs3287D] अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent

For Appellant: Shri E.V. Sri Krishna, ARFor Respondent: Ms. L. Sunitha Rao, CIT-DR
Section 143(3)Section 40

आदेश / ORDER PER K. NARASIMHA CHARY, J.M: Aggrieved by the final assessment order dated 17/03/2021 passed consequent to the directions of Hon'ble Dispute Resolution Panel, Bengaluru (“DRP”), in the case of M/s. Satyam Venture Engineering Services Pvt. Ltd., (“the assessee”) for the assessment year 2016-17, under section

Ishares Msci Em Ucits Etf Usd Dist, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation)-2(2)(2), Mumbai

In the result appeal of the assessee is partly allowed

ITA 4570/MUM/2023[2021-22]Status: DisposedITAT Mumbai31 May 2024AY 2021-22

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

Section 111ASection 143Section 144C

learned AO) in pursuance of directions passed under section 144C (5) of the income tax act issued by the dispute resolution panel – I, Mumbai (the learned DRP) dated 13 September 2023 wherein the total income of the assessee is assessed at 1,85,28,212/– instead of the return income ... 4570/Mum/2023 iShares MSCI EM VCITS ETF USD Acc; A.Y. 2021-22 010. Assessee preferred objection before the learned dispute resolution panel where directions were issued on 12/9/2023 rejecting the assessee's objection and upheld the action of the AO in taxing the gross amount of short-term capital gain chargeable

Ishares Msci Em Imi Esg Screened Ucits Etf, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation)-2(2)(2), Mumbai

In the result appeal of the assessee is partly allowed

ITA 4569/MUM/2023[2021-22]Status: DisposedITAT Mumbai31 May 2024AY 2021-22

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

Section 111ASection 143Section 144C

learned AO) in pursuance of directions passed under section 144C (5) of the income tax act issued by the dispute resolution panel – I, Mumbai (the learned DRP) dated 13 September 2023 wherein the total income of the assessee is assessed at 1,85,28,212/– instead of the return income ... 4570/Mum/2023 iShares MSCI EM VCITS ETF USD Acc; A.Y. 2021-22 010. Assessee preferred objection before the learned dispute resolution panel where directions were issued on 12/9/2023 rejecting the assessee's objection and upheld the action of the AO in taxing the gross amount of short-term capital gain chargeable

Ishares Msci Em Ucits Etf Usd Acc, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation)-2(2)(2), Mumbai

In the result appeal of the assessee is partly allowed

ITA 4568/MUM/2023[2021-22]Status: DisposedITAT Mumbai31 May 2024AY 2021-22

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

Section 111ASection 143Section 144C

learned AO) in pursuance of directions passed under section 144C (5) of the income tax act issued by the dispute resolution panel – I, Mumbai (the learned DRP) dated 13 September 2023 wherein the total income of the assessee is assessed at 1,85,28,212/– instead of the return income ... 4570/Mum/2023 iShares MSCI EM VCITS ETF USD Acc; A.Y. 2021-22 010. Assessee preferred objection before the learned dispute resolution panel where directions were issued on 12/9/2023 rejecting the assessee's objection and upheld the action of the AO in taxing the gross amount of short-term capital gain chargeable

Ishares Msci India Ucits Etf, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation)-2(2)(2), Mumbai

In the result appeal of the assessee is partly allowed

ITA 4567/MUM/2023[2021-22]Status: DisposedITAT Mumbai31 May 2024AY 2021-22

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

Section 111ASection 143Section 144C

learned AO) in pursuance of directions passed under section 144C (5) of the income tax act issued by the dispute resolution panel – I, Mumbai (the learned DRP) dated 13 September 2023 wherein the total income of the assessee is assessed at 1,85,28,212/– instead of the return income ... 4570/Mum/2023 iShares MSCI EM VCITS ETF USD Acc; A.Y. 2021-22 010. Assessee preferred objection before the learned dispute resolution panel where directions were issued on 12/9/2023 rejecting the assessee's objection and upheld the action of the AO in taxing the gross amount of short-term capital gain chargeable

Ishares Emsc Mauritius Co, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation )-2(2)(2), Mumbai

In the result appeal of the assessee is partly allowed

ITA 4564/MUM/2023[2021-22]Status: DisposedITAT Mumbai31 May 2024AY 2021-22

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

Section 111ASection 143Section 144C

learned AO) in pursuance of directions passed under section 144C (5) of the income tax act issued by the dispute resolution panel – I, Mumbai (the learned DRP) dated 13 September 2023 wherein the total income of the assessee is assessed at 1,85,28,212/– instead of the return income ... 4570/Mum/2023 iShares MSCI EM VCITS ETF USD Acc; A.Y. 2021-22 010. Assessee preferred objection before the learned dispute resolution panel where directions were issued on 12/9/2023 rejecting the assessee's objection and upheld the action of the AO in taxing the gross amount of short-term capital gain chargeable

Veeratham Sachdev, New Delhi vs. DCIT Circle International Taxation, New Delhiq

In the result, both the appeal of the assessee are allowed for

ITA 390/DEL/2023[2016-17]Status: DisposedITAT Delhi31 May 2024AY 2016-17

Bench: Dr. Brr Kumar & Shri Sudhir Pareek

For Appellant: Shri Harshit Chauhan, AdvFor Respondent: Shri Vijay B Vasanta, CIT- DR

additions of the investments made in SBI Mutual Fund and BNP Paribas Mutual Fund. 5. Aggrieved, the assessee filed objection with the Learned Dispute Resolution Panel (Ld. DRP). 6. The Ld. DRP vide order dated 05.12.2022, directed the AO to pass a speaking order after examining the explanation

Veeratham Sachdev, New Delhi vs. DCIT Circle International Taxation, New Delhi

In the result, both the appeal of the assessee are allowed for

ITA 374/DEL/2023[2013-14]Status: DisposedITAT Delhi31 May 2024AY 2013-14

Bench: Dr. Brr Kumar & Shri Sudhir Pareek

For Appellant: Shri Harshit Chauhan, AdvFor Respondent: Shri Vijay B Vasanta, CIT- DR

additions of the investments made in SBI Mutual Fund and BNP Paribas Mutual Fund. 5. Aggrieved, the assessee filed objection with the Learned Dispute Resolution Panel (Ld. DRP). 6. The Ld. DRP vide order dated 05.12.2022, directed the AO to pass a speaking order after examining the explanation

Zydus Lifesciences Ltd.(in Case of Liva Healthcare Ltd-Now Amalgamated With Zydus Lifesciences Ltd.), Ahmedabad vs. The Dy.CIT., Central Circle-2(1), Ahmedabad

In the result, appeal preferred by the assessee is allowed

ITA 702/AHD/2023[2009-10]Status: DisposedITAT Ahmedabad30 May 2024AY 2009-10

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 702/Ahd/2023 ("नधा"रण वष" / Assessment Years:2009-10)

For Appellant: Shri Mukesh Patel & Shri Jigar PatelFor Respondent: Ms.Saumya Pandey Jain, Sr.D.R
Section 143(3)Section 37

various doctors all over the country. He further observed that the A.O. while disallowing the expenditure, relied on. the orders of the DRP (Dispute Resolution Panel) in the case of two other companies namely, (i) Glaxo Pharma and Merck Pharma. However, it had not been pointed

Zydus Lifesciences Limited (Formerly Known As Cadila Healthcare Ltd.), Ahmedabad vs. The DCIT, Circle-1(1)(1), Ahmedabad

In the result, appeal preferred by the assessee is allowed

ITA 162/AHD/2021[2016-17]Status: DisposedITAT Ahmedabad30 May 2024AY 2016-17

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 162/Ahd/2021 ("नधा"रण वष" / Assessment Years : 2016-17)

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 144BSection 144C(13)Section 153Section 92BSection 92C

Year 2016-17. 2. The maintainability of the very proceeding is under challenge before us to this effect that the Transfer Pricing Officer / Dispute Resolution Panel (‘DRP’) has erred in exceeding the jurisdiction by passing the transfer pricing order under Section 92CA(3) of the Act beyond the mandatory prescribed ... Mumbai against the said draft order issued under Section 144C of the Act dated 12.12.2019. The Hon’ble Dispute Resolution Panel- 2, Mumbai passed order under Section 144C(5) of the Act dated 19.03.2021 issuing certain directions to the Ld. AO on very many issues. Subject to the same

Uttam Energy Limited, Pune vs. ACIT Circle-12, Pune

Appeal of the Assessee is partly allowed

ITA 2033/PUN/2019[2015-16]Status: DisposedITAT Pune30 May 2024AY 2015-16

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2033/Pun/2019 िनधा"रण वष" / Assessment Year: 2015-16 Uttam Energy Limited, The Acit, Circle-12, Mahendra Chamber, Mayfair V Pune. Co-Op Housing Society, S A-4, Dhole Patil Road, Pune – 411001. Pan: Aabcu4100H Appellant/ Revenue Respondent /Assessee Assessee By Shri Ch Naniwadekar & Kiran Sanmane – Ar;S Revenue By Shri Deepak Garg – Cit Date Of Hearing 16/05/2024 Date Of Pronouncement 30/05/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Has Been Filed By The Assessee Against The Final Assessment Order Of The Learned Acit, Circle-12, Pune Passed U/Sec. 143(3) R.W.S. 144C(13) Of The Of The Income Tax Act, 1961 (In Short "The Act") After Giving Effect To The Learned Drp’S Order Dated 24.09.2019. 1.1 The Assessee Has Raised The Following Grounds Of Appeal :

Section 143(3)Section 153Section 153(1)Section 40A(2)(b)Section 92BSection 92C

raised the following grounds of appeal : ITA No.2033/PUN/2019 / Uttam Energy Limited [A] “1. The learned Assessing Officer acting under directions of leaned Dispute Resolution Panel erred both on facts and in law in making adjustment under section 92C as the section 92BA (i) of the IT Act has been omitted ... barred by limitation in terms of section 153 (1) of the IT Act. 3. The learned Assessing Officer acting under directions of leaned Dispute Resolution Panel erred both on facts and in law in confirming the addition of Rs.4,00,00,000 by holding that the appellant’s specified domestic

Jesudason Biji, Chennai vs. Office of Income Tax Officer Int. Taxn Ward1(1), Chennai

In the result, appeal filed by the assessee is allowed

ITA 567/CHNY/2024[2014-15]Status: DisposedITAT Chennai30 May 2024AY 2014-15

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Shri M.V.Swaroop, AdvocateFor Respondent: Shri D. Hema Bhupal, JCIT
Section 119(2)(b)Section 139(1)Section 139(5)Section 147Section 148Section 148ASection 149Section 54ESection 54F

hereinafter ‘AY’) 2014-15 u/s.147 r.w.s.144C(13) of the Income Tax Act, 1961 (hereinafter ‘the Act’) by order dated 05.01.2024 pursuant to the Dispute Resolution Panel-2 (hereinafter ‘DRP’), Bangalore, dated 22.12.2023. ITA No.567 /Chny/2024 for AY 2014-15 & SP No.24/Chny/2024 for AY 2014-15 Shri Jesudason Biji

Kony Inc, United States of America vs. Deputy Commissioner of Income-Tax, Chennai

In the result, appeal filed by the assessee is allowed

ITA 1572/CHNY/2023[AY 2021-22]Status: DisposedITAT Chennai30 May 2024

Bench: Shri Mahavir Singh, Hon’Ble & Shri S. R. Ragunatha, Hon’Bleआयकर अपील सं./Ita No.: 1572/Chny/2023 िनधा"रण वष" / Assessment Year: 2021-22 Kony Inc., Deputy Commissioner Of 5301, Southwest Parkway, V. Income Tax, Suite 250, International Taxation -1(2), Austin, Texas, Chennai. Usa - 5301 [Pan: Aaeck-4771-D] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. R. Sivaraman, Advocate : Shri. D. Hema Bhupal, Jcit ""यथ" क" ओर से/Respondent By सुनवाई क" तारीख/Date Of Hearing : 24.04.2024 घोषणा क" तारीख/Date Of Pronouncement : 30.05.2024

For Appellant: Shri. R. Sivaraman, Advocate
Section 143(2)Section 143(3)Section 144C

provisions of sub section (2) of section 144C, the assessee is required to file its acceptance or file its objections before the Dispute Resolution Panel and to the Assessing Officer within 30 days of the receipt of the draft assessment order. However, the assessee has not filed any objections with

Gartner Ireland Limited, Mumbai vs. Deputy Comm. of Income Tax-2(3)(2), Mumbai

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

ITA 2460/MUM/2022[2019-20]Status: DisposedITAT Mumbai30 May 2024AY 2019-20

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2019-2020 Gartner Ireland Ltd., Dcit-2(3)(2), 3Rd Floor, Two Park Place, 17Th Floor, 1711, Air India Hatch Street, Dublin 2, Vs. Building, Nariman Point, Ireland D02 Np94. Mumbai-400021. Pan No. Aaccg 2919 B Appellant Respondent Assessee By : Mr. Farooq Irani Revenue By : Mr. A.K. Ambastha, Sr. Dr : Date Of Hearing 12/04/2024 : Date Of Pronouncement 30/05/2024

For Appellant: Mr. Farooq IraniFor Respondent: Mr. A.K. Ambastha, Sr. DR
Section 234DSection 9(1)(vi)

Commissioner of Income-tax-International Taxation Circle 2(3)(2), Mumbai (in short ‘the Assessing Officer’) pursuant to the direction of the Ld. Dispute Resolution Panel (DRP) dated 15.06.2022 for assessment year 2019-2020. 2. The grounds raised by the assessee in its appeal are reproduced as under: Gartner Ireland

Titan Company Limited 9Earstwhile Known As Titan Industries Limited), Krishnagiri vs. ACIT Ltu 1, Chennai

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

ITA 518/CHNY/2018[2009-10]Status: DisposedITAT Chennai29 May 2024AY 2009-10

Bench: Shri Mahavir Singhand Shri Amitabh Shukla

For Appellant: Shri T. Surya Narayana, AdvocateFor Respondent: Shri A. Sasikumar, CIT
Section 143(3)

claimed was debited to the Hosur Unit since the 801C Units cater to domestic market. This issue came up in appeal before the Dispute Resolution Panel(DRP), Chennai, and the Hon'ble DRP in its order in DRP/Chennai/44/2012 dated 31.08,2012 issued directions in this regard as follows: “Based

Titan Company Limited 9Earstwhile Known As Titan Industries Limited), Krishnagiri vs. ACIT Ltu 1, Chennai

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

ITA 507/CHNY/2018[2012-13]Status: DisposedITAT Chennai29 May 2024AY 2012-13

Bench: Shri Mahavir Singhand Shri Amitabh Shukla

For Appellant: Shri T. Surya Narayana, AdvocateFor Respondent: Shri A. Sasikumar, CIT
Section 143(3)

claimed was debited to the Hosur Unit since the 801C Units cater to domestic market. This issue came up in appeal before the Dispute Resolution Panel(DRP), Chennai, and the Hon'ble DRP in its order in DRP/Chennai/44/2012 dated 31.08,2012 issued directions in this regard as follows: “Based

Titan Company Limited 9Earstwhile Known As Titan Industries Limited), Krishnagiri vs. ACIT Ltu 1, Chennai

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

ITA 506/CHNY/2018[2011-12]Status: DisposedITAT Chennai29 May 2024AY 2011-12

Bench: Shri Mahavir Singhand Shri Amitabh Shukla

For Appellant: Shri T. Surya Narayana, AdvocateFor Respondent: Shri A. Sasikumar, CIT
Section 143(3)

claimed was debited to the Hosur Unit since the 801C Units cater to domestic market. This issue came up in appeal before the Dispute Resolution Panel(DRP), Chennai, and the Hon'ble DRP in its order in DRP/Chennai/44/2012 dated 31.08,2012 issued directions in this regard as follows: “Based