“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

Sabre Glbl Inc., New Delhi vs. DCIT (International Taxation), New Delhi

In the result, all the appeals of the assessee are allowed and that of the Revenue stands dismissed

ITA 559/DEL/2017[2013-14]Status: HeardITAT Delhi09 Feb 2024AY 2013-14

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmaita No. 216/Del/2016, A.Y. 2012-13 Ita No. 559/Del/2017, A.Y. 2013-14 Ita No. 4838/Del/2017, A.Y. 2014-15 Ita No. 7724/Del/2018, A.Y. 2015-16 Ita No. 6040/Del/2019, A.Y. 2016-17 Sabre Glbl Inc. Vs. Asstt. Commissioner Of Income Mr. Tarandeep Singh, Tax, Adv. Circle-3(1)(2), C/O. Ms Associates, International Tax F-99, Lajpat Nagar-Ii, New Delhi New Delhi Pan : Aaact7216Q (Appellant) (Respondent) Deputy Commissioner Of Vs. Sabre Glbl Inc. Income Tax, Mr. Tarandeep Singh, Adv. International Taxation, C/O. Ms Associates, New Delhi F-99, Lajpat Nagar-Ii, New Delhi-110024 Pan : Aaact7216Q (Appellant) (Respondent) Assessee By Sh. Tarandeep Singh, Adv. Revenue By Sh. Vizay B. Vasanta, Cit-Dr

Section 143(2)Section 143(3)Section 144C(1)

30th September, 2015. 7. That on facts and in law the order passed by Assessing Officer {hereinabove referred to as the “AO”} and Dispute Resolution Panel {hereinabove referred to as the “DRP”} are bad in law and void ab- initio. That the appellant prays for leave to add, alter, amend

Sabre Glbl Inc., New Delhi vs. DCIT (International Taxation), Circle- 3(1)(2), New Delhi

In the result, all the appeals of the assessee are allowed and that of the Revenue stands dismissed

ITA 4838/DEL/2017[2014-15]Status: HeardITAT Delhi09 Feb 2024AY 2014-15

Section 143(2)Section 143(3)Section 144C(1)

Sabre Inc, New Delhi vs. DCIT (International Taxation), New Delhi

In the result, all the appeals of the assessee are allowed and that of the Revenue stands dismissed

ITA 216/DEL/2016[2012-13]Status: HeardITAT Delhi09 Feb 2024AY 2012-13

Section 143(2)Section 143(3)Section 144C(1)

DCIT (International Taxation), New Delhi vs. M/S. Sabre Glbl Inc., Gurgaon

In the result, all the appeals of the assessee are allowed and that of the Revenue stands dismissed

ITA 6731/DEL/2015[2012-13]Status: HeardITAT Delhi09 Feb 2024AY 2012-13

Section 143(2)Section 143(3)Section 144C(1)

Lovely Promoters Private Limited, Kolkata vs. ACIT, Central Circle, Ajmer

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

ITA 770/JPR/2023[2013-14]Status: DisposedITAT Jaipur08 Feb 2024AY 2013-14

Bench: him regarding non mentioning of Document Identification Number (DIN) in the body of the order u/s. 127 of the Act dated 08-09-2021 and various other technical pleas raised in grounds of appeal regarding validity of notice u/s. 148 of the Act, thereby appellate order passed by the CIT(A) is non-speaking order and deserves to be quashed. 4. On the facts and in circumstances of the case and in law, the AO erred in issuing notice u/s. 148 of the Act as it was a search related case u/s. 132 r/w

For Appellant: Shri Mayank Taparia (Adv.)For Respondent: Shri A.S. Nehra (Addl.CIT) a

Section 127Section 127(1)Section 132Section 147Section 148Section 148ASection 151Section 153C

draft assessment order was passed on 30.12.2018. 15. The respondent/assessee had filed its objections qua the same, which were disposed of by the Dispute Resolution Panel [DRP] via order dated 20.09.2019. 29 Lovely promoters Pvt. Ltd. vs. ACIT 16. The final assessment order was passed by the Assessing Officer

Huhtavefa B.V, Netherlands vs. ACIT, Circle Int. Taxation 2(1)(1), New Delhi

In the result, the Assessee’s Appeal is partly allowed for statistical purposes

ITA 3118/DEL/2023[2021-22]Status: DisposedITAT Delhi08 Feb 2024AY 2021-22

Bench: Shri Shamim Yahya

For Appellant: Shri Malay Kalavadia, AdvFor Respondent: Shri Vijay B. Vasanta, CIT-DR

Section 142(1)Section 143(2)Section 143(3)Section 234ASection 234BSection 234CSection 270A

learned AO"), under section 143(3) r.w.s 144C(13) of Income-tax Act, 1961 ('the Act') in pursuance to directions issued by the Dispute Resolution Panel - 1 New Delhi ("the DRP") on the following grounds: Ground No. 1-Ground of appeal pertaining to favorable benefit of lower tax rate

Castrol India Ltd, Mumbai vs. NFAC, Delhi

In the result, the issue under consideration is remitted back to the file of Assessing Officer for statistical purpose

ITA 2433/MUM/2022[2018-19]Status: DisposedITAT Mumbai07 Feb 2024AY 2018-19

Bench: Shri Vikas Awasthy, Hon’Ble & Shri S. Rifaur Rahman, Hon'Blecastrol India Limited V. National Faceless Appeal Centre Technopolis Knowledge Park Delhi Mahakali Caves Road Chakala, Andheri (E) Mumbai – 400093 Pan: Aaacc4481E (Appellant) (Respondent) Assessee Represented By : Shri Dhanesh Bafna, Ms. Chandni Shah, Shri Hardik Nirmal & Ms. Riddhi Maru Department Represented By : Ms. A. Alankrutha

Section 115Section 143(3)Section 144C(5)Section 92C

RIFAUR RAHMAN (AM) 1. This appeal is filed by the assessee against the final Assessment Order and directions of the Dispute Resolution Panel of Learned Castrol India Limited Commissioner of Income Tax (DRP-1), Mumbai-1 [hereinafter in short “Ld.DRP”] dated 22.06.2022 for the A.Y.2018-19 passed u/s. 144C ... closing balance as per the Balance Sheet (Refer P No. 8 of the Draft Assessment Order). Subsequently, the Dispute Resolution Panel (the DRP), has deleted the proposed addition of ₹.10,14,49,891 after considering contentions raised by the assessee such as: “1.9.1. Disallowance of closing balance

Air Liquide Global Ec Germany Gmbh, Germany vs. ACIT, Circle International Tax 1(1)(1), New Delhi

In the result, the appeal is allowed and the stay application is

ITA 2401/DEL/2023[2020-21]Status: DisposedITAT Delhi07 Feb 2024AY 2020-21

Bench: Shri Saktijit Dey, Vice- & Shri M. Balaganeshassessment Year: 2020-21

Section 144C(13)Section 44B

read with section 144C(13) of the Income-tax Act, 1961 pertaining to assessment year 2020-21, in pursuance to directions of learned Dispute Resolution Panel (DRP). 2. The core issue arising in the appeal relates to taxability of the amount received by the assessee from offshore supplies of plants

Fulford (India) Ltd, Mumbai vs. DCIT Cir 2(1), Mumbai

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

ITA 338/MUM/2014[2009-10]Status: DisposedITAT Mumbai06 Feb 2024AY 2009-10

Bench: Shri Vikas Awasthy & Shri Gagan Goyalआ.अ.सं.338/मुं/2014(िन.व.2009-10) Fulford (India) Limited, Platina Building, 8Th Floor, C-59, G-Block, Bandra Kurla Complex, Bandra (East), Mumbai – 400 098 Pan: Aaacf-1795-L ...... अपीलाथ"/Appellant बनाम Vs. Dy.Commissioner Of Income Tax, Circle 2(1), Room No.561, 5Th Floor, Aaykar Bhavan, M.K.Road, Mumbai – 400 020. ..... "ितवादी/Respondent Assessee By : Shri P.J. Pardiwala, Sr. Advocate With Shri Madhur Agrawal, Advocate Revenue By : Dr. Yogesh Kamat, Cit-Dr & Shri Ujjwal Kumar Chavan, Sr.Ar सुनवाई क" ितिथ/ Date Of Hearing : 10/11/2023 घोषणा क" ितिथ/ Date Of Pronouncement : 06/02/2024 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Assessment Order Dated 13/12/2013 Passed U/S. 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961 [In Short ‘The Act’], For The Assessment Year 2009-10. 2. The Facts Of The Case In Brief Are: The Assessee/Appellant Is Engaged In The Business Of Manufacturing & Distribution Of Pharmaceutical Products In 2 India. The Assessee Is A Subsidiary Of Schering-Plough Corporation, Usa. During The Period Relevant To The Assessment Year Under Appeal, The Assessee Entered Into Various International Transactions With Its Associated Enterprise(Ae). During The Course Of Assessment Proceedings The Transfer Pricing Officer (Tpo) Made Adjustment In Respect Of Following International Transactions: Sl.No. Description Of International Transaction Adjustment Made By Tpo (Amount In Rs.) 1. Import Of Active Pharmaceutical 4,81,96,325 Ingredients (Apis) 2 Import Of Finished Drug Formulations (Fdf) 15,75,53,000 Total 20,57,49,325

For Appellant: Shri P.J. Pardiwala, Sr. Advocate with Shri Madhur Agrawal, AdvocateFor Respondent: Dr. Yogesh Kamat, CIT-DR &

Section 143(3)

APIs) 2 Import of Finished Drug Formulations (FDF) 15,75,53,000 Total 20,57,49,325 The assessee filed objections before the Dispute Resolution Panel(DRP) assailing the adjustments but the same were rejected. Hence, the present appeal by the assessee. 3. The assessee in appeal has raised following

Tata International Ltd, Mumbai vs. Addl CIT 7(3), Mumbai

Appeal of the assessee is partly allowed for statistical purposes

ITA 537/MUM/2013[2008-09]Status: DisposedITAT Mumbai06 Feb 2024AY 2008-09

Bench: Shri Amit Shukla & Shri Gagan Goyaltata International Ltd., Block A, Shivsagar Estates Dr. Annie Besant Road, Worli, Mumbai- 400018, Pan: Aaact3198F ...... Appellant Vs. Acit – 7(3), R. No. 675, 6Th Floor, Aayakar Bhavan, M. K. Marg Mumbai- 400020 ..... Respondent

For Appellant: Shri Nitesh Joshi a/w Ninad PatadeFor Respondent: Shri Anoop Hiwase, Ld. DR

Section 144CSection 36(1)Section 36(1)(iii)

Date of pronouncement : 06/02/2024 O R D E R PER GAGAN GOYAL, A.M: This appeal by assessee is directed against the order of Dispute Resolution Panel – II, Mumbai dated 25.09.2011 u/s. 144C (5) of the Income Tax Act, 1961 (in short ‘the Act’) for A.Y. 2008-09. 2 TATA INTERNATIONAL ... learned Assessing Officer and/or the learned Dispute Resolution Panel ["AO-DRP"] erred in disallowing expenditure aggregating 3, 74, 855 by way of payments made to clubs. 2. This ground raised by the assessee is covered by the decision of Coordinate Bench of ITAT Mumbai in assessee's own case

New Skies Satellites B.V., Gurgaon vs. DCIT, Circle-2(2)(2), International Taxation, New Delhi

In the result, appeal of the assessee is partly allowed

ITA 2944/DEL/2022[2020-21]Status: DisposedITAT Delhi06 Feb 2024AY 2020-21

Bench: Shri G.S.Pannu & Shri Kul Bharat[Assessment Year : 2020-21] New Skies Satellites B.V., Vs Dcit, C/O-Ernst & Young Llp, Golf Cirlce-2(2)(2), View Corporate Tower, Tower-B, International Taxation, Sector-42, Gurgaon, New Delhi. Haryana-122002. Pan-Aaccn1866C Appellant Respondent Appellant By Ms. Ananya Bajpayee, Adv. Respondent By Shri Bhuvnesh Kulshrestha, Cit Dr & Shri Om Prakash, Sr.Dr Date Of Hearing 12.01.2024 Date Of Pronouncement 06.02.2024

Section 139(1)Section 143(1)Section 2Section 234ASection 270ASection 9(1)(vi)

raised following grounds of appeal:- “1. That on the facts and in the circumstances of the case and in law, the Ld. Dispute Resolution Panel ('the Panel') erred in not directing the Learned Assessing Officer ('Ld. AO') to pass appropriate orders holding that the Appellant is not liable ... royalty and the AO also treated the same as fee for technical services. Aggrieved against this, the assessee filed objections before Ld. Dispute Resolution Panel (“DRP”) who following the order of the earlier year 3 | P a g e and confirmed the adjustment. Thereafter, the AO vide impugned order

Honda Motorcycle and Scooter India Pvt. Ltd., Gurgaon vs. ACIT, Circle-1(1), Gurugram

In the result, appeal is partly allowed

ITA 1524/DEL/2022[2018-19]Status: DisposedITAT Delhi05 Feb 2024AY 2018-19

Bench: Shri Saktijit Dey, Vice- & Shri Pradip Kumar Kediaassessment Year: 2018-19

For Appellant: Sh. Harpreet Singh Ajmani, AdvFor Respondent: Sh. Rajesh Kumar, CIT-DR

Section 143(3)Section 92C

under section 143(3) of the Income-tax Act, 1961 pertaining to assessment year 2018-19, in pursuance to the directions of learned Dispute Resolution Panel (DRP). 2. Ground Nos. 1 & 2, being general grounds, do not require specific adjudication. 2 3. Grounds Nos. 3 to 8 relate to addition ... application of the principles of commercial expediency and need test applied by the learned transfer pricing officer and confirmed by the learned dispute resolution panel. The ground number 6 along with its sub- grounds (14 in number) is in substance challenging the determination of the arm's-length price

M/S Glenmark Pharmaceuticals Ltd., Mumbai vs. DCIT (Ltu)-1, Mumbai

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

ITA 575/MUM/2020[2014-15]Status: DisposedITAT Mumbai01 Feb 2024AY 2014-15

Bench: Shri B.R. Baskaran (Am) & Shri Rahul Chaudhary (Jm)

Section 144ASection 32ASection 35Section 37(1)Section 80I

transfer pricing adjustments and also various other additions. Since the assessee did not prefer to object the draft assessment order before Ld Dispute Resolution Panel, the AO passed the final assessment order. The Glenmark Pharmaceuticals Ltd. appeal filed by the assessee before Ld CIT(A) was partly allowed. Hence both

Avinash Kumar, Jamshedpur, Jharkhand vs. A.C.I.T., Circle - 2(1), Kolkata

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

ITA 1629/KOL/2024[2018-2019]Status: DisposedITAT Kolkata31 Jan 2024AY 2018-2019

Bench: Shri Rajesh Kumar, Am & Shri Sonjoy Sarma, Jm Acit, Circle 2(1) Avinash Kumar Aaykar Bhavan, P-7, Flat No.D/5, B Block, Shiv Kumar Asthali, Phase Ii, Nh-33 Road, Chowringhee Square, 7 Th Vs. Mango, Jamshedpur, Floor, Kolkata-700069 Jharkhand-831012 West Bengal (Appellant) (Respondent) Pan No. Bifpk4983A Assessee By : Shri Manoj Soni, Ar Revenue By : Shri Gaurav Kanaujia, Dr Date Of Hearing: 16.01.2025 Date Of Pronouncement : 31.01.2025

For Appellant: Shri Manoj Soni, ARFor Respondent: Shri Gaurav Kanaujia, DR

Section 144C(1)Section 144C(13)Section 147Section 55Section 56(2)(x)

Rajesh Kumar, AM: This is an appeal preferred by the assessee against the order of the Dispute Resolution Panel-2, New Delhi (ld. DRP) dated 20.12.2023 for the AY 2018-19. 02. At the outset, we note that there is the delay of 134 days in filing the appeal ... delay in filing the appeal of the assessee. 03. The only issue raised by the assessee is against the order of ld. Dispute Resolution Panel, confirming the order of the ld. AO, wherein the addition of ₹12,52,900/- was made

Nat West Markets Plc- India Branch, Kolkata vs. ACIT(I.T)-1(2), Kolkata.

In the result, the appeal of the assessee is allowed

ITA 1364/KOL/2023[2021-22]Status: DisposedITAT Kolkata31 Jan 2024AY 2021-22

Bench: Shri Rajesh Kumar, Am & Shri Sonjoy Sarma, Jm Nat West Markets Plc-India Acit (I.T)-1(2), Kolkata Branch Aaykar Bhavan Poorva, 2 Nd 907, Regus, 9Thfloor, Floor, Psarcadia,4A, Abandindra Nath Vs. 110, Shanti Pally, Thakur Sarani, Kolkata-700016, Kolkata-700107, West Bengal West Bengal (Appellant) (Respondent) Pan No. Aacct8020E Assessee By : Shri Percy Pardiwala, Ar Revenue By : Shri Gaurav Kanujia, Dr Date Of Hearing: 15.01.2025 Date Of Pronouncement : 31.01.2025

For Appellant: Shri Percy Pardiwala, ARFor Respondent: Shri Gaurav Kanujia, DR

Section 143(3)Section 144C(13)Section 44ASection 56Section 68

Rajesh Kumar, AM: This is an appeal preferred by the assessee against the order of the ld. Dispute Resolution Panel (hereinafter referred to as the “Ld. DRP”] dated 26.09.2023 for the AY 2021-22. 02. The only issue raised in ground no.1 is against the order of ld. AO passed ... pursuance to the direction of the ld. Dispute Resolution Panel adding the interest on income tax refund amounting to ₹62,12,73,000/- to the income of the assessee by ignoring the fact that the same is related to the erstwhile Indian Branches of The Royal Bank of Scotland

Dy Commissioner of Income Tax -8(3)(1), Mumbai vs. M/S Welspun Global Brands Ltd, Mumbai

ITA 2182/MUM/2022[2011-12]Status: DisposedITAT Mumbai31 Jan 2024AY 2011-12

Bench: Shri.Narender Kumar Choudhry () & Miss. Padmavathy S.() Ι.Τ.Α. No.2073/Mum/2022 (Assessment Year : 2011-12) M/S Welspun Global Brands Ltd Vs 9Th Floor, Welspun House, Kmala Mill Compound, Senapati Bapat Marg, Lower Parel, Mumbai-400 013 Pan: Aabcb5226F Appellant Dcit-8(3)(2), Mumbai Respondent Ι.Τ.Α. Νο.2182/Mum/2022 (Assessment Year : 2011-12) Deputy Commissioner Of Income Tax-8(3)(1), Mumbai Aayakar Bhavan, Room No.615 M.K. Road, New Marine Lines, Mumbai-400 020 Appellant Vs M/S Welspun Global Brands Ltd 9Th Floor, Welspun House, Kmala Mill Compound, Senapati Bapat Marg, Lower Parel, Mumbai-400 013 Pan: Aabcb5226F Respondent Present For The Assessee Shri. Percy Pardiwala, Ld.Sr.Counsel Alongwith Harsh Kapadia, Ca Present For The Department Shri. Nihar Samal, Ld. Sr.Dr Date Of Hearing 24/01/2024 Date Of Pronouncement 31/01/2024 2

Section 143(3)Section 144CSection 14ASection 250Section 92C

filed before the Assessing Officer claimed as under:- “4.4 We do not wish to file any objections against the aforesaid order before the Dispute Resolution Panel as set out in 144C of the I.T. Act, 1961. However, we shall be filing an appeal before the CIT(A)." 8. Considering ... Assessee has specifically claimed that it does not wish to avail any objections against the order passed by the TPO before the Dispute Resolution Panel (DRP) as per provisions of section 144C of the Act, no draft order was passed by AO but in fact direct final assessment order dated

Welspun Global Brands Ltd, Mumbai vs. DCIT - CC 3(3), Mumbai

ITA 2073/MUM/2022[2011-12]Status: DisposedITAT Mumbai31 Jan 2024AY 2011-12

Bench: Shri.Narender Kumar Choudhry () & Miss. Padmavathy S.()

Section 143(3)Section 144CSection 14ASection 250Section 92C

The Great Eastern Shipping Co. Ltd, Mumbai vs. Asst CIT Cir 5(3)(2), Mumbai

ITA 1596/MUM/2018[2013-14]Status: DisposedITAT Mumbai31 Jan 2024AY 2013-14

Section 143(3)Section 14ASection 43B

IN THE INCOME TAX APPELLATE TRIBUNAL, ‘K’ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & SHRI S.RIFAUR RAHMAN, ACCOUNTANT MEMBER

Bechtel Power Corporation, United States vs. ACIT Circle-Internationa Taxation 1(1)(2), New Delhi

In the result, all the four appeals are allowed on this

ITA 796/DEL/2021[2017-18]Status: DisposedITAT Delhi31 Jan 2024AY 2017-18

Bench: Shri G.S. Pannu, Vice- & Shri Saktijit Dey, Vice-

For Appellant: Sh. Deepak Chopra, AdvFor Respondent: Sh. Vizay B. Vasanta, CIT-DR &

796/Del/2021 ORDER Captioned appeals by two different assessees challenge the final assessment orders passed in pursuance to the directions of the learned Dispute Resolution Panel (DRP) for the assessment years 2016-17 and 2017-18. 2. Since the facts and issues involved in all these appeals are, more or less ... proceeded to pass the final assessment order under Section 143(3) of the Act. 34. In Vijay Television (P) Ltd v. Dispute Resolution Panel, Chennai (2014) 369 ITR 113 (Mad) where again the AO passed the final assessment order under Section 143 (3) of the Act instead of passing

Bechtel Limited, United Kingdom vs. ACIT Circle- International Taxation 1(1)(2), New Delhi

In the result, all the four appeals are allowed on this

ITA 795/DEL/2021[2017-18]Status: DisposedITAT Delhi31 Jan 2024AY 2017-18

Bench: Shri G.S. Pannu, Vice- & Shri Saktijit Dey, Vice-

For Appellant: Sh. Deepak Chopra, AdvFor Respondent: Sh. Vizay B. Vasanta, CIT-DR &