“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

Th Boston Consulting Group (India) P. Ltd, Mumbai vs. DCIT Cir 3(3)(2), Mumbai

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

ITA 1401/MUM/2016[2011-12]Status: DisposedITAT Mumbai03 May 2024AY 2011-12

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Sunil Kumar Singh, Hon'Blethe Boston Consulting Group (India) V. Dcit – Circle - 3(3)(2) Private Limited Aayakar Bhavan, M.K. Road 14Th Floor, Nariman Bhavan Mumbai - 400020 227, Nariman Point Mumbai - 400021 Pan: Aabcb3524G (Appellant) (Respondent) Assessee Represented By : Shri J.D. Mistri, Shri Pratik Shah & Ms. Riddhi Maru Department Represented By : Shri Udoal Raj Singh

Section 143(3)Section 234BSection 234DSection 244ASection 271(1)

learned AO'/ the learned Additional Commissioner of Income-tax Transfer Pricing 4(2) ('the learned TPO'), under the directions of the Hon'ble Dispute Resolution Panel - 2 ('the Hon'ble DRP'), erred in determining the arm's length price of the Appellant's international transaction of provision of management consultancy

Jcdecaux S.A., New Delhi vs. ACIT, Circle-2(1)(2), International Taxation, New Delhi

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

ITA 2473/DEL/2022[2018-19]Status: DisposedITAT Delhi03 May 2024AY 2018-19

Bench: Dr. B. R. R. Kumarms. Astha Chandra

For Appellant: Sh. K. M. Gupta, Adv. &For Respondent: Sh. Om Parkash, Sr. DR

Section 143(3)Section 234BSection 270ASection 9(1)(vii)

facts and in the circumstances of the case and in law, the Ld. AO and Ld. Dispute Resolution Panel (DRP'), have grossly erred in holding that the Management Fee' amounting to Rs. 2,39,09,103 is taxable as 'Fees for Technical Services' (FTS) as per the Double Taxation Avoidance

Sony Pictues Netorks India P. Ltd., Mumbai vs. Addl/Jt/Dy/Asstt/CIT/ITO, National E-Assessment Centre Delhi (Now Known As National Faceless Assessment Centre), Delhi

In the result, both the appeals of the assessee are treated as allowed

ITA 925/MUM/2021[2016-17]Status: DisposedITAT Mumbai02 May 2024AY 2016-17

Bench: Justice (Retd.) C V Bhadang, Hon’Ble& Shri B.R. Baskaran: A.Y : 2015-16 : A.Y : 2016-17

For Appellant: Shri Percy Pardiwala with Shri Nitesh Joshi &For Respondent: Shri Salil Mishra – CIT-DR

Section 143(3)

assessment years 2015-16 and 2016-17 u/s 143(3) r.w.s 144C of the Act in pursuance of directions given by Ld Dispute Resolution Panel (DRP). Since common issues are urged in both these appeals, they were heard together and are being disposed of by this common order

Sony Pictures Networks India Pvt Ltd., Mumbai vs. Asst CIT CC 3 (2), Mumbai

In the result, both the appeals of the assessee are treated as allowed

ITA 7685/MUM/2019[2015-16]Status: DisposedITAT Mumbai02 May 2024AY 2015-16

Bench: Justice (Retd.) C V Bhadang, Hon’Ble& Shri B.R. Baskaran

For Appellant: Shri Percy Pardiwala withFor Respondent: Shri Salil Mishra - CIT-DR

Section 143(3)

Mankind Pharma Limited, Delhi vs. DCIT, Circle-1(1)(1), Meerut

In the result, the additional Ground No

ITA 2313/DEL/2022[2018-19]Status: DisposedITAT Delhi01 May 2024AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri Pradip Kumar Kedia

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Shri Rajesh Kumar, CIT (DR)

Section 143(3)Section 144BSection 144C(13)Section 153(3)Section 270ASection 35Section 80GSection 80I

Section 144C(13) r.w. Section 144B of the Income Tax Act (in short ‘the Act’) in pursuance of directions issued by Dispute Resolution Panel (DRP) dated 21.06.2022 relevant to Assessment Year 2018-19. 2. The grounds of appeal raised by the assessee read as under: “1. That the assessing officer ... Duty Drawback 2,18,481 10. On receipt of the draft order, the assessee filed its objection to such variations with the Dispute Resolution Panel (DRP). 11. Pursuant to reference made by the Assessee, the DRP issued its direction dated 21.06.2022 wherein the view of the TPO that there existed

Openwave Mobility, Inc., Gurgaon vs. DCIT, Circle Int. Taxation 2(2)(2), New Delhi

In the result, appeal of the assessee is allowed

ITA 1644/DEL/2022[2019-20]Status: DisposedITAT Delhi01 May 2024AY 2019-20

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year: 2019-20

For Appellant: Shri Gaurav Singhal, AdvFor Respondent: Shri Vizay B. Vasanta, CIT-DR

Section 143(3)Section 144C(10)

passed under section 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (the “Act”) in pursuance to the directions of Ld. Dispute Resolution Panel (“DRP”) pertaining to the Assessment Year (“AY”) 2019-20. 2. The assessee has raised the following grounds of appeal:- “1. That the Deputy Commissioner ... erred in law, in passing the assessment order without following the directions issued by the Dispute Resolution Panel -2 ('Hon'ble DRP) dated 17 May 2022 wherein the Hon'ble DRP has directed the Ld. AO to not make addition on account of the software license fees received

Renault Nissan Technology & Business Centre India Private Limited, Kanchipuram vs. ACIT, Corporate Circle 5(1), Chennai

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

ITA 914/CHNY/2023[2011-12]Status: DisposedITAT Chennai30 Apr 2024AY 2011-12

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. Nos.913 & 914/Chny/2023 िनधा"रण वष"/Assessment Years: 2010-11 & 2011-12 Renault Nissan Technology & Vs. The Assistant Commissioner Of Business Centre India Private Limited, Income Tax, Corporate Circle 5(1), Tp2/1, Ascendas It Park, Natham Main Building, Aayakar Bhavan, Sub Post Office, Mahindra World City, No. 121, M.G. Road, Kanchipuram District, Nungambakkam, Chennai 600 034. Tamil Nadu 603 004. [Pan:Aadcr7253E] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Ashik Shah, C.A. ""थ" की ओर से/Respondent By : Shri Nilay Baran Som, Cit सुनवाई की तारीख/ Date Of Hearing : 24.04.2024 घोषणा की तारीख /Date Of Pronouncement : 30.04.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Appeals Filed By The Assessee Against Separate Orders Both Dated 23.06.2023 Passed By The Nfac [Cit(A)] For The Assessment Year 2010-11 & 2011-12 Respectively.

For Appellant: Shri Ashik Shah, C.AFor Respondent: Shri Nilay Baran Som, CIT

Section 10A

determining the assessed income at ₹.20,68,24,860/-. The assessee, being aggrieved by the draft Assessment Order, filed an application before the Dispute Resolution Panel (hereinafter 'the DRP' for brevity). The DRP accepted the case of the assessee and issued directions dated 20.12.2013, directing the Assessing Officer

Renault Nissan Technology& Business Centre India Private Limited, Kanchipuram vs. ACIT, Corporate Circle 5(1), Chennai

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

ITA 913/CHNY/2023[2010-11]Status: DisposedITAT Chennai30 Apr 2024AY 2010-11

For Appellant: Shri Ashik Shah, C.AFor Respondent: Shri Nilay Baran Som, CIT

Section 10A

Satish Babu Kannan, Bengaluru vs. ITO, Intnl Taxn Ward-1(2), Chennai

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

ITA 370/CHNY/2023[2015-16]Status: DisposedITAT Chennai30 Apr 2024AY 2015-16

Bench: Shri Mahavir Singhand Shri S.R. Raghunatha

For Appellant: Shri D. Anand, Advocate &For Respondent: Shri V. Nandakumar, CIT

Section 142(1)Section 144CSection 147Section 148Section 195

Taxation 1(2), Chennai u/s.147 r.w.s.144C(13) of the Income Tax Act, 1961 (hereinafter the ‘Act’) in pursuant to the directions of the Dispute Resolution Panel-2, Bengaluru dated 12.12.2022.. 2. At the outset, the ld.counsel for the assessee made arguments that the AO has made additions of application ... provisions of sub section (2) of section 144C of the Income Tax Act, 1961 read with rule 4 of the Income Tax (Dispute Resolution Panel) Rules, 2009, it is clear that the assessee needs to file the objection and paper book in person or through his agent before

Skybridge Solutions Private Limited, Hyderabad vs. DCIT, (Tp)-2 Hyderbad, Hyderabad

In the result, the appeal of the assessee is dismissed

ITA 184/HYD/2024[2021-22]Status: DisposedITAT Hyderabad29 Apr 2024AY 2021-22

Bench: Shri Laliet Kumar(Through Virtual Mode) & Shri Madhusudan Sawdia, Accounant Member Assessment Year: 2021-22 Skybridge Solutions Vs. The Deputy Commissioner Of Private Limited, Income Tax, Hyderabad, (Transfer Pricing)-2, H.No.8-2-239/L/83-A, Hyderabad. Plot No.83/A, Mla Colony, Road No.12, Banjara Hills, Hyderabad – 500034, Telangana. Pan : Aalcs1899M. (Appellant) (Respondent) Assessee By: Shri Mahesh Raichandani, C.A. Revenue By: Ms. K. Haritha, Cit-Dr Date Of Hearing: 23.04.2024 Date Of Pronouncement: 29.04.2024 O R D E R Per Laliet Kumar, J.M. The Appeal Of The Assessee For A.Y. 2021-22 Arises From The Impugned Assessment Order Passed U/S 143(3) R.W.S. 144C(3) R.W.S. 144B Of The Income Tax Act Dated 26.12.2023. 2. The Brief Facts Of The Case Are That The Assessee Is A Software Development & Services Company, Filed Its Income Tax Return For The Assessment Year 2021-22 On 09.03.2022, Declaring A Total Income Of Rs.1,06,49,030. The Return Was Processed Under Section 143(1)(A) Of The Income Tax Act On 24.08.2022. Subsequently, The Case Was Selected For Scrutiny Under Cass & A Notice Under Section 143(2) Was Issued On 28.06.2022, To Which The Assessee Responded On 15.07.2023. Thereafter, A Reference Under Section 92Ca(1) Was Made To The Transfer Pricing Officer (Tpo) To Determine The Arm'S Length Price For Transactions With Associated Enterprises. The Tpo, Through An Order Dated 31.10.2023, Directed An Upward Adjustment Of Rs.1,83,25,993 To The Assessee'S Income For The Financial Year 2020-21. Consequently, A Show Cause Notice Was Issued To The Assessee On November 9, 2023, Regarding The Proposed Adjustment, Along With A Penalty Initiation Under Section 270A.

For Appellant: Shri Mahesh Raichandani, C.AFor Respondent: Ms. K. Haritha, CIT-DR

Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 144CSection 147Section 154Section 253(1)(d)Section 270A

order passed by an Assessing Officer under sub-section (3), of section 143 or section 147 in pursuance of the directions of the Dispute Resolution Panel or an order passed under section 154 in respect of such order.] [ Inserted by Act 33 of 2009, Section 73 (w.e.f ... drawn our attention to sections 144C(1) to 144C(5) of the Act, which are to the following effect: “144C Reference to dispute resolution panel (1) The Assessing Officer shall, notwithstanding anything to the contrary contained in this Act, in the first instance, forward a draft of the proposed order

Concentrix Services India Private Limited (Formerly Known As Minacs Private Limited, Minacs Limited and Aditya Birla Minacs Worldwide Limited), Mumbai vs. DCIT 10(2)(2), Mumbai

In the result, the additional ground of appeal of the assessee is dismissed

ITA 1235/MUM/2015[2010-11]Status: DisposedITAT Mumbai29 Apr 2024AY 2010-11

Bench: Shri Aby T. Varkey, Jm & Shri S Rifaur Rahman, Am आयकर अपील सं/ I.T.A. No.1235/Mum/2015 (निर्धारण वर्ा / Assessment Year: 2010-11) Concentrix Services India बिधम/ Dcit-10(2)(2) Pvt. Ltd Room No. 209, Aayakar Vs. (Formerly Known As Minacs Bhavan, M. K. Road, Pvt. Ltd, Minacs Limited Churchgate, Mumbai- & Aditya Birla Minacs 400020. Worldwide Limited) 9Th Floor, Symphony It Park, Chandivali Farm Road, Andheri (E), Mumbai-400072. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaact1567A (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Chaitanya Joshi & Riken Shah Revenue By: Shri P. Sudhakar Naik सुनवाई की तारीख / Date Of Hearing: 01/04/2024 घोषणा की तारीख /Date Of Pronouncement: 29/04/2024 आदेश / O R D E R Per Aby T. Varkey, Jm: This Appeal Is Filed By The Assessee Against The Assessment Order Passed U/S 143(3) Read With Section 144C(13) Of The Income Tax Act, 1961 (Hereinafter “The Act”) Dated 30.01.2015 Passed By The Dcit- 10(2)(2), Mumbai For Ay. 2010-11, Pursuant To Direction Of The Dispute Resolution Panel-1, Mumbai (Hereinafter “The Ld. Drp”) Dated 27.10.2014. 2. At The Outset, The Ld. Ar Has Brought To Our Notice That This Appeal Of The Assessee Company For The Relevant Year I.E. Ay. 2010-11 Was Partly Allowed By This Tribunal Vide Order Dated 12.06.2023. & Thereafter, The Assessee Preferred A Miscellaneous Application (Ma)

For Appellant: Shri Chaitanya Joshi & Riken ShahFor Respondent: Shri P. Sudhakar Naik

Section 143(3)Section 144C(13)Section 37

hereinafter “the Act”) dated 30.01.2015 passed by the DCIT- 10(2)(2), Mumbai for AY. 2010-11, pursuant to direction of the Dispute Resolution Panel-1, Mumbai (hereinafter “the Ld. DRP”) dated 27.10.2014. 2. At the outset, the Ld. AR has brought to our notice that this appeal

M/S. Atul Ltd., Ahmedabad vs. The Dy.CIT, Circle-1(1)(2), Ahmedabad

The appeal of the assessee is partly allowed in the above terms for statistical purpose

ITA 446/AHD/2015[2010-11]Status: DisposedITAT Ahmedabad26 Apr 2024AY 2010-11

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarit(Tp)A No.446/Ahd/2015 Assessment Year : 2010-11 M/S.Atul Limited Dcit, Cir.1(1)(2) Atul House Vs Ahmedabad. Gi Patel Marg Ahmedabad 380 014. Pan : Aabca 2390 M

For Appellant: Shri S.N. Soparkar, Sr.Advocate &For Respondent: Dr.Darsi Suman Ratnam, CIT-DR

Section 143(3)Section 144Section 92C

associate enterprises by the Transfer Pricing Officer in his order passed u/s 92CA(3) of the Act and • the directions of the Dispute Resolution Panel on the objections raised by the assessee to the additions proposed by the AO in his draft assessment order in terms of section

Toyoda Gosei Company, Japan vs. Deputy Commissioner of Income Tax, International Taxation, Circle 2(2), Bengaluru

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

ITA 1092/BANG/2023[2021-22]Status: DisposedITAT Bangalore24 Apr 2024AY 2021-22

Bench: Shri Chandra Poojari & Smt Beena Pillai

For Appellant: Shri Rohit Tiwari, AdvocateFor Respondent: Shri G. Manoj Kumar, CIT-DR

Section 143(3)Section 192Section 9(1)(vii)Section 90

under section 143(3) r.w.s. 144C(13) of the Income tax Act, 1961 (`the Act') pursuant to the directions of the Ld. Dispute Resolution Panel (`Ld. DRP') is bad in law, unlawful and unjust. 2. On the facts and circumstances of the case

Gorakshan Sabha, Nagpur vs. Commissioner of Income Tax (Appeals) Income Tax Department, National Faceless Appeal Centre (NFAC), Mof, Goi

In the result, appeal of the assessee is dismissed

ITA 92/NAG/2023[2014-15]Status: DisposedITAT Nagpur23 Apr 2024AY 2014-15

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.92 & 91/Nag/2023 िनधा"रण वष" / Assessment Years : 2014-15 & 2013-14 Gorakshan Sabha, The Income Tax Officer, Near Hitawada Press, V Ward Exemption, Nagpur. Wardha Road, Dhantoli, S Nagpur – 440012. Pan: Aaatg2927L Appellant/ Assessee Respondent/Revenue Assessee By None Revenue By Shri Abhay Y. Marathe - Sr.Dr Date Of Hearing 28/03/2024 Date Of Pronouncement 23/04/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By The Assessee Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac] Under Section 250 Of The Act, Emanating From The Common Intimation Of Outstanding Demand Order For A.Y.2014-15 & 2013-14 Respectively. Since Facts Of Both Appeals Are Similar, We Take Up Appeal For A.Y.2014-15 As

Section 115VSection 115WSection 143Section 144Section 144BSection 147Section 200ASection 206CSection 246ASection 250

adjustments, or any order of assessment under sub-section (3) of section 143 [except an order passed in pursuance of directions of the Dispute Resolution Panel or an order referred to in sub-section (12) of section 144BA] or section 144, to the income assessed, or to the amount ... section 115WG; (b) an order of assessment, reassessment or recomputation under section 147 [except an order passed in pursuance of directions of the Dispute Resolution Panel or an order referred to in sub-section (12) of section 144BA] or section 150; (ba) an order of assessment or reassessment under section

Gorakshan Sabha, Nagpur, Wardha Road vs. Commissioner of Income Tax (Appeals) Income Tax Department, National Faceless Appeal Centre (NFAC), Mof, Goi

In the result, appeal of the assessee is dismissed

ITA 91/NAG/2023[2013-14]Status: DisposedITAT Nagpur23 Apr 2024AY 2013-14

Section 115VSection 115WSection 143Section 144Section 144BSection 147Section 200ASection 206CSection 246ASection 250

Tech Data (Singapore) Pte Limited (Formerly Known As "Technology Solutions (Singapore) Pte Limited), Mumbai vs. The Deputy Commissioner of Income Tax, International Tax Circle-4(1)(2), Mumbai

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

ITA 3280/MUM/2023[2020-21]Status: DisposedITAT Mumbai23 Apr 2024AY 2020-21

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

For Appellant: Nitesh JoshiFor Respondent: Anil Sant

Section 143(2)Section 143(3)Section 144CSection 234ASection 234BSection 270ASection 274

DTAA taxable at 10% of the rate prescribed in the DTAA. 5. Against the draft assessment order the assessee filed objection before the Dispute Resolution Panel (DRP). However, the DRP vide direction issued u/s 144C(5) of the Act dated 28.06.2023 has rejected the objection filed by the assessee

Indira Pasupuleti, Palakollu vs. Income Tax Officer, International Taxation, Kakinada

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

ITA 8/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam19 Apr 2024AY 2016-17

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./ I.T.A. No.08/Viz/2024 (निर्धारण वर्ा / Assessment Year : 2016-17) Indira Pasupuleti, Vs. Income Tax Officer, Palakollu. International Taxation, Pan: Gfjpp 5413 L Kakinada. (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधर्थी की ओर से/ Appellant By : Sri C. Subrahmanyam, Ar प्रत्यधर्थी की ओर से / Respondent By : Dr. Aparna Villuri, Sr. Ar

For Appellant: Sri C. Subrahmanyam, ARFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 142(1)Section 144C(1)Section 144C(3)Section 144C(5)Section 147Section 148Section 56(2)(vii)

assessment order of the Ld. Assessing Officer in DIN & Order No. ITBA/AST/S/147/2023-24/1058339709(1), dated 30/11/2023 arising out of the directions of the Ld. Dispute Resolution Panel [in short Ld. DRP] given U/s. 144C(5) of the Income Tax Act, 1961 [the Act] for the AY 2016-17. 2 2. Briefly ... being aggrieved, against the draft assessment order, the assessee filed objections U/s. 144C(3) of the Act before the Ld. Dispute Resolution Panel, Bengaluru. After considering the submissions of the assessee and the remand report obtained from the Ld. AO, the Ld. DRP passed order U/s. 144C

Dy. Commissioner of Income Tax, Circle 1(1), Pune, Swargate vs. Grupo Antolin India Private Limited, Pune

The appeal of the Revenue is allowed for statistical purposes in above terms

ITA 1118/PUN/2023[2012-13]Status: DisposedITAT Pune18 Apr 2024AY 2012-13

Bench: Hon’Ble Shri G. D. Padmahshali & Hon’Ble Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No. 1118/Pun/2023 निर्धारण वषा / Assessment Year : 2012-13 Dy. Commissioner Of Income Tax, Central Circle-1(2), Pune . . . . . . . अपीलार्थी / Appellant

For Appellant: Mr Dhanraj Dangi [‘Ld. AR’]For Respondent: Mr Akhilesh Srivastava [‘Ld. DR’]

Section 143(2)Section 143(3)Section 246A(1)Section 250Section 253(2)Section 92C

claimed by the appellant. In consequence an upward TP adjustment was proposed and since the assessee did not dispute it before Dispute Resolution Panel [in short ‘DRP’] the assessment was framed incorporating such upward TP adjustment & assessed total income accordingly. The appellant later assailed the upward TP adjustment

Saab Technologies B.V.(Formerly Known S, Kolkata vs. D.C.I.T., International Taxation, Circle-2(1), Kolkata

In the result, ITA No. 153/KOL/2022 is allowed

ITA 153/KOL/2022[2018-2019]Status: DisposedITAT Kolkata18 Apr 2024AY 2018-2019

Bench: Sri Anikesh Banerjee & Sri Girish Agrawal

Section 143(3)Section 144C

brevity the ‘Act’) for assessment year 2018-19. The impugned order was in persuasion of the order of the Hon'ble Dispute Resolution Panel- 2, New Delhi dated 27.12.2021. 2. The assessee has taken the following grounds of appeal: I.T.A. No.: 153/KOL/2022 Assessment Year: 2018-19 Saab Technologies B.V (Formerly ... assessment order under Section 143(3) read with Section 144C 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 merely

Balusa Venkata Muralikrishna, Bangalore vs. The Incometax Offcier, Intl Taxn, Ward1(2), Bangalore, Koramangala

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

ITA 252/BANG/2024[2015-16]Status: DisposedITAT Bangalore17 Apr 2024AY 2015-16

Bench: Shri Chandra Poojari & Shri Soundararajan K.

For Appellant: Smt. Suman Lunkar, A.RFor Respondent: Sri Sunil Kumar Agarwal, D.R

Section 147Section 148Section 148ASection 45Section 54F

capital gain” u/s 45 of the Act. A draft assessment order was passed on 28.8.2023 against which the assessee filed objections before the Dispute Resolution Panel (“DRP”), Bangalore and the ld. DRP after getting the remand report from the ld. AO had rejected all the grounds raised by the assessee