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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

Dialog Axiata Plc, Mumbai vs. The Dy Commissioner of Income Tax, International Taxation-2(1)(1), Mumbai

ITA 2643/MUM/2022[2012-13]Status: DisposedITAT Mumbai15 Jan 2024AY 2012-13

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

Section 144CSection 147Section 191Section 195Section 5

section 5 of the Act, the said receipts are to be taxed as 'royalty'. 4. The assessee filed its objection before the learned Dispute Resolution Panel ('ld. DRP' for short) challenging the draft assessment order passed by the ld. A.O. The ld. DRP disposed off the objections raised

Strides Shasun Ltd, Navi Mumbai vs. DCIT Cir 15(3)(2), Mumbai

In the result, appeal of assessee is partly allowed

ITA 932/MUM/2017[2012-13]Status: DisposedITAT Mumbai15 Jan 2024AY 2012-13

Bench: Shri Vikas Awasthy& Shri Amarjit Singhआअसं.932 /मुं/2017 (िन.व. 2012-13) Strides Pharma Science Limited [Formerly Known As Strides Arcolab Limited/ Strides Shasun Limited] 201, Devavrata, Sector -17, Vashi, Navi Mumbai – 400 703 Pan: Aadcs-8104-P ...... अपीलाथ"/Appellant बनाम Vs. The Deputy Commissioner Of Income Tax Circle – 15(3)(2), Mumbai Room No.451, 4Th Floor, Aaykar Bhavan, M.K.Road, Mumbai – 400 020 ..... "ितवादी/Respondent अपीलाथ" "ारा/ Appellant By : Shri Nitesh Joshi, Advocate With Shri Ninand Patade "ितवादी "ारा/Respondent By : Shri Anoop Hiwase सुनवाई क" ितिथ/ Date Of Hearing : 26/10/2023 घोषणा क" ितिथ/ Date Of Pronouncement : 15 /01/2024 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Final Assessment Order Dated 23/01/2017 Passed U/S. 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961 [In Short ‘The Act’], For The Assessment Year 2012-13. 2. The Assessee In Appeal Has Raised As Many As 12 Grounds. Shri Nitesh Joshi, Advocate Appearing On Behalf Of The Assessee Submitted At The Outset

For Appellant: Shri Nitesh Joshi, Advocate with Shri Ninand PatadeFor Respondent: Shri Anoop Hiwase
Section 143(3)

decided on 28/06/2023. 3. Per contra, Shri Anoop Hiwase representing the Department strongly supported the findings of the Assessing Officer and Dispute Resolution Panel (DRP) in the impugned assessment year. However, he fairly stated that the issues raised in the present appeal by the assessee have been considered ... petitioner has at the beginning of today's hearing itself undertaken to withdraw its objection on the issue of jurisdiction before the Dispute Resolution Panel. This was accepted by us before considering the issue on the merits. Moreover, this petition was filed on April 24, 2013, challenging the impugned orders

The Tata Power Co. Ltd, Mumbai vs. Addl CIT RG 2(3), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 753/MUM/2013[2008-09]Status: DisposedITAT Mumbai12 Jan 2024AY 2008-09

Bench: Shri Vikas Awasthy& Ms. Padmavathy.Sआअसं.753/मुं/2013 (िन.व. 2008-09) The Tata Power Co. Ltd. Corporate Center, Block ‘B’, 5Th Floor, 34, Sant Thukaram Road, Carnak Bunder, Mumbai 400 009. Pan: Aaact-0054-A ...... अपीलाथ"/Appellant बनाम Vs. Additional Commissioner Of Income Tax, Range 2(3), Mumbai. Aaykar Bhavan, M.K.Road, Mumbai – 400 020 ....."ितवादी/Respondent

For Appellant: Shri Nitesh Joshi with Shri Ninad PatadeFor Respondent: Shri Manoj Kumar&
Section 143(3)Section 14ASection 14A(2)

further made additions/disallowances under various provisions of the Act. Aggrieved by the draft assessment order dated 29/12/2011, the assessee filed objections before the Dispute Resolution Panel (DRP). The DRP vide directions dated 28/09/2012 granted part relief to the assessee. The Assessing Officer passed the final impugned assessment order, accordingly

DCIT, New Delhi vs. I Energizer Holdings Ltd., New Delhi

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

ITA 4653/DEL/2015[2011-12]Status: DisposedITAT Delhi11 Jan 2024AY 2011-12

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

144C(15)(b) of the Income Tax Act, 1961. The said provision reads as under: “(15) For the purposes of this section,— (a) "Dispute Resolution Panel" means a collegium comprising of three Commissioners of Income-tax constituted by the Board for this purpose; (b) "eligible assessee" means,— (i ) any person ... file his acceptance of the variations to the Assessing Officer; or (b) file his objections, if any, to such variation with,— (i) the Dispute Resolution Panel; and (ii) the Assessing Officer. (3) The Assessing Officer shall complete the assessment on the basis of the draft order, if— (a) the assessee

DCIT, New Delhi vs. I Energizer Holdings Ltd., New Delhi

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

ITA 4652/DEL/2015[2010-11]Status: DisposedITAT Delhi11 Jan 2024AY 2010-11

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

144C(15)(b) of the Income Tax Act, 1961. The said provision reads as under: “(15) For the purposes of this section,— (a) "Dispute Resolution Panel" means a collegium comprising of three Commissioners of Income-tax constituted by the Board for this purpose; (b) "eligible assessee" means,— (i ) any person ... file his acceptance of the variations to the Assessing Officer; or (b) file his objections, if any, to such variation with,— (i) the Dispute Resolution Panel; and (ii) the Assessing Officer. (3) The Assessing Officer shall complete the assessment on the basis of the draft order, if— (a) the assessee

DCIT, New Delhi vs. I Energizer Holdings Ltd., New Delhi

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

ITA 4651/DEL/2015[2009-10]Status: DisposedITAT Delhi11 Jan 2024AY 2009-10

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

144C(15)(b) of the Income Tax Act, 1961. The said provision reads as under: “(15) For the purposes of this section,— (a) "Dispute Resolution Panel" means a collegium comprising of three Commissioners of Income-tax constituted by the Board for this purpose; (b) "eligible assessee" means,— (i ) any person ... file his acceptance of the variations to the Assessing Officer; or (b) file his objections, if any, to such variation with,— (i) the Dispute Resolution Panel; and (ii) the Assessing Officer. (3) The Assessing Officer shall complete the assessment on the basis of the draft order, if— (a) the assessee

DCIT, New Delhi vs. I Energizer Holdings Ltd., New Delhi

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

ITA 4650/DEL/2015[2008-09]Status: DisposedITAT Delhi11 Jan 2024AY 2008-09

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

144C(15)(b) of the Income Tax Act, 1961. The said provision reads as under: “(15) For the purposes of this section,— (a) "Dispute Resolution Panel" means a collegium comprising of three Commissioners of Income-tax constituted by the Board for this purpose; (b) "eligible assessee" means,— (i ) any person ... file his acceptance of the variations to the Assessing Officer; or (b) file his objections, if any, to such variation with,— (i) the Dispute Resolution Panel; and (ii) the Assessing Officer. (3) The Assessing Officer shall complete the assessment on the basis of the draft order, if— (a) the assessee

Marvell India Private Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle-4(1)(2), Bangalore

In the result, appeal of the assessee is partly allowed

ITA 343/BANG/2021[2016-17]Status: DisposedITAT Bangalore10 Jan 2024AY 2016-17

Bench: Shri George George K & Shri Chandra Poojariit(Tp)A No.343/Bang/2021 Assessment Year : 2016-17 M/S. Marvell India Pvt. Ltd., Vs. Acit, Tower D, 10Th & 11Th Floors, Circle – 4(1)(2), Global Technoloyg Park, Marathahalli – Bengaluru. Sarjapur Outer Ring Road, Bellandur, Bengaluru – 560 103. Pan : Aaecm 5559 R Appellant Respondent Assessee By : Shri. Mukesh Butani, Advocate Revenue By : Shri. G. Manoj Kumar, Cit(Dr)(Itat), Bengaluru Date Of Hearing : 10.01.2024 Date Of Pronouncement : 10.01.2024 O R D E R Per George George K:

For Appellant: Shri. Mukesh Butani, AdvocateFor Respondent: Shri. G. Manoj Kumar, CIT(DR)(ITAT), Bengaluru
Section 143(2)Section 143(3)Section 144CSection 92C

Order, a Draft Assessment Order was passed under section 144C of the Act on 21.12.2019. 3. Aggrieved, assessee filed objections before the Dispute Resolution Panel (DRP) (objections dated 20.01.2020). The DRP, vide its directions dated 2025.03.2021, dismissed the objections raised by the assessee and confirmed the TPO adjustment proposed

Crisil Ltd, Mumbai vs. Asst CIT RG 9(2)(2), Mumbai

ITA 1345/MUM/2017[2012-13]Status: DisposedITAT Mumbai10 Jan 2024AY 2012-13

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bleιτα.Νο. 7603/Mum/2012 (A.Y: 2008-09) M/S. Crisil Limited 8Th Floor, Central Avenue Road Hiranandani Business Park Opp. D-Mart, Powai Mumbai- 400076 Pan: Aaaст3151E (Appellant) V. Addl. Cit - 8(1) Aayakar Bhavan, M.K. Road Mumbai- 400020 (Respondent) Ιτα.Νο. 1564/Mum2014 (A.Y: 2009-10) M/S. Crisil Limited Central Avenue Road Hiranandani Business Park Opp. D-Mart, Powai Mumbai- 400076 Pan: Aaaст3151E (Appellant) V. Dy. Cit (Osd) – 8(1) Aayakar Bhavan, M.K. Road Mumbai- 400020 (Respondent)

Section 133(6)Section 144C(5)

appeals relating to A.Y. 2008-09 and 2012-13 are filed by assessee against final Assessment Order and directions of the Learned Dispute Resolution Panel – 1, Mumbai [hereinafter in short “Ld.DRP"] dated 26.09.2012 and 25.11.2016 for the A.Y.2008-09 and 2012-13 respectively, passed u/s. 144C(5) of Income ... provision of back-end support for data analysis services. 12. Aggrieved with the above order of Transfer Pricing Officer, assessee preferred objection before Dispute Resolution Panel and filed detailed submissions. After considering the submissions of the assessee, Ld. DRP upheld the order of the Transfer Pricing Officer and affirmed

Crisil Ltd, Mumbai vs. DCIT 9(2)(2), Mumbai

ITA 997/MUM/2016[2011-12]Status: DisposedITAT Mumbai10 Jan 2024AY 2011-12

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bleιτα.Νο. 7603/Mum/2012 (A.Y: 2008-09) M/S. Crisil Limited V. Addl. Cit - 8(1) 8Th Floor, Central Avenue Road Aayakar Bhavan, M.K. Road Hiranandani Business Park Mumbai- 400020 Opp. D-Mart, Powai Mumbai- 400076 (Respondent) Pan: Aaaст3151E (Appellant) Ιτα.Νο. 1564/Mum2014 (A.Y: 2009-10) M/S. Crisil Limited V. Dy. Cit (Osd) – 8(1) Central Avenue Road Aayakar Bhavan, M.K. Road Hiranandani Business Park Mumbai- 400020 Opp. D-Mart, Powai Mumbai- 400076 (Respondent) Pan: Aaaст3151E (Appellant)

Section 133(6)Section 144C(5)

appeals relating to A.Y. 2008-09 and 2012-13 are filed by assessee against final Assessment Order and directions of the Learned Dispute Resolution Panel – 1, Mumbai [hereinafter in short “Ld.DRP"] dated 26.09.2012 and 25.11.2016 for the A.Y.2008-09 and 2012-13 respectively, passed u/s. 144C(5) of Income ... provision of back-end support for data analysis services. 12. Aggrieved with the above order of Transfer Pricing Officer, assessee preferred objection before Dispute Resolution Panel and filed detailed submissions. After considering the submissions of the assessee, Ld. DRP upheld the order of the Transfer Pricing Officer and affirmed

Asst CIT RG 9(2)(1), Mumbai vs. Crisil Ltd, Mumbai

In the result the issue under

ITA 843/MUM/2015[2010-11]Status: DisposedITAT Mumbai10 Jan 2024AY 2010-11

Bench: Shri Aby T Varkey, Hon'Ble

Section 133(6)Section 144C(5)

appeals relating to A.Y. 2008-09 and 2012-13 are filed by assessee against final Assessment Order and directions of the Learned Dispute Resolution Panel — 1, Mumbai [hereinafter in short “Ld.DRP”] dated 26.09.2012 and 25.11.2016 for the A.Y.2008-09 and 2012-13 respectively, passed u/s. 144C(5) of Income ... provision of back-end support for data analysis services. 12. Aggrieved with the above order of Transfer Pricing Officer, assessee preferred objection before Dispute Resolution Panel and filed detailed submissions. After considering the submissions of the assessee, Ld. DRP upheld the order of the Transfer Pricing Officer and affirmed

Crisil Ltd, Mumbai vs. Asst CIT RG 9(2)(2), Mumbai

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

ITA 1114/MUM/2015[2010-11]Status: DisposedITAT Mumbai10 Jan 2024AY 2010-11

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 133(6)Section 144C(5)

appeals relating to A.Y. 2008-09 and 2012-13 are filed by assessee against final Assessment Order and directions of the Learned Dispute Resolution Panel – 1, Mumbai [hereinafter in short “Ld.DRP”] dated 26.09.2012 and 25.11.2016 for the A.Y.2008-09 and 2012-13 respectively, passed u/s. 144C(5) of Income ... provision of back-end support for data analysis services. 12. Aggrieved with the above order of Transfer Pricing Officer, assessee preferred objection before Dispute Resolution Panel and filed detailed submissions. After considering the submissions of the assessee, Ld. DRP upheld the order of the Transfer Pricing Officer and affirmed

Crisil Ltd, Mumbai vs. DCIT (OSD) 8(1), Mumbai

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

ITA 1564/MUM/2014[2009-10]Status: DisposedITAT Mumbai10 Jan 2024AY 2009-10

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 133(6)Section 144C(5)

appeals relating to A.Y. 2008-09 and 2012-13 are filed by assessee against final Assessment Order and directions of the Learned Dispute Resolution Panel – 1, Mumbai [hereinafter in short “Ld.DRP”] dated 26.09.2012 and 25.11.2016 for the A.Y.2008-09 and 2012-13 respectively, passed u/s. 144C(5) of Income ... provision of back-end support for data analysis services. 12. Aggrieved with the above order of Transfer Pricing Officer, assessee preferred objection before Dispute Resolution Panel and filed detailed submissions. After considering the submissions of the assessee, Ld. DRP upheld the order of the Transfer Pricing Officer and affirmed

DCIT RG (OSD) 8(1), Mumbai vs. Crisil Ltd, Mumbai

ITA 1180/MUM/2014[2009-10]Status: DisposedITAT Mumbai10 Jan 2024AY 2009-10

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bleιτα.Νο. 7603/Mum/2012 (A.Y: 2008-09) M/S. Crisil Limited 8Th Floor, Central Avenue Road Hiranandani Business Park Opp. D-Mart, Powai Mumbai- 400076 Pan: Aaaст3151E (Appellant) V. Addl. Cit - 8(1) Aayakar Bhavan, M.K. Road Mumbai- 400020 (Respondent) Ιτα.Νο. 1564/Mum2014 (A.Y: 2009-10) M/S. Crisil Limited Central Avenue Road Hiranandani Business Park Opp. D-Mart, Powai Mumbai- 400076 V. Dy. Cit (Osd) – 8(1) Aayakar Bhavan, M.K. Road Mumbai- 400020 (Respondent) Pan: Aaaст3151E (Appellant)

Section 133(6)Section 144C(5)Section 92C(2)

appeals relating to A.Y. 2008-09 and 2012-13 are filed by assessee against final Assessment Order and directions of the Learned Dispute Resolution Panel – 1, Mumbai [hereinafter in short “Ld.DRP"] dated 26.09.2012 and 25.11.2016 for the A.Y.2008-09 and 2012-13 respectively, passed u/s. 144C(5) of Income ... provision of back-end support for data analysis services. 12. Aggrieved with the above order of Transfer Pricing Officer, assessee preferred objection before Dispute Resolution Panel and filed detailed submissions. After considering the submissions of the assessee, Ld. DRP upheld the order of the Transfer Pricing Officer and affirmed

Crisil Ltd, Mumbai vs. Addl CIT 8(1), Mumbai

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

ITA 7603/MUM/2012[2008-09]Status: DisposedITAT Mumbai10 Jan 2024AY 2008-09

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 133(6)Section 144C(5)

appeals relating to A.Y. 2008-09 and 2012-13 are filed by assessee against final Assessment Order and directions of the Learned Dispute Resolution Panel – 1, Mumbai [hereinafter in short “Ld.DRP”] dated 26.09.2012 and 25.11.2016 for the A.Y.2008-09 and 2012-13 respectively, passed u/s. 144C(5) of Income ... provision of back-end support for data analysis services. 12. Aggrieved with the above order of Transfer Pricing Officer, assessee preferred objection before Dispute Resolution Panel and filed detailed submissions. After considering the submissions of the assessee, Ld. DRP upheld the order of the Transfer Pricing Officer and affirmed

Petrofac International Uae Llc, Gurgaon vs. DCIT, Int. Taxation, Gurgaon

In the result, the appeal is partly allowed

ITA 1894/DEL/2023[2020-21]Status: DisposedITAT Delhi10 Jan 2024AY 2020-21

Bench: Shri Saktijit Dey, Vice- & Dr. B.R.R. Kumarassessment Year: 2020-21

Section 143(3)Section 144C(13)Section 43A

read with section 144C(13) of the Income-tax Act, 1961 (in short ‘the Act’) in pursuance to the directions of learned Dispute Resolution Panel (DRP) pertaining to assessment year 2020-21. AY: 2020-21 2. Ground no. 1, being a general ground, does not require adjudication. 3. Insofar

DCIT, New Delhi vs. Iservices Investments Ltd., New Delhi

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

ITA 5396/DEL/2015[2011-12]Status: DisposedITAT Delhi10 Jan 2024AY 2011-12

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

144C(15)(b) of the Income Tax Act, 1961. The said provision reads as under: “(15) For the purposes of this section,— (a) "Dispute Resolution Panel" means a collegium comprising of three Commissioners of Income-tax constituted by the Board for this purpose; (b) "eligible assessee" means,— (i ) any person ... file his acceptance of the variations to the Assessing Officer; or (b) file his objections, if any, to such variation with,— (i) the Dispute Resolution Panel; and (ii) the Assessing Officer. (3) The Assessing Officer shall complete the assessment on the basis of the draft order, if— (a) the assessee

DCIT, New Delhi vs. M/S Wickwood Development Ltd., New Delhi

ITA 3357/DEL/2015[2009-10]Status: DisposedITAT Delhi10 Jan 2024AY 2009-10

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

Section 153CSection 6(3)(ii)

144C(15)(b) of the Income Tax Act, 1961. The said provision reads as under: “(15) For the purposes of this section, — (a) "Dispute Resolution Panel" means a collegium comprising of three Commissioners of Income-tax constituted by the Board for this purpose; (b) "eligible assessee" means, — (i) any person ... file his acceptance of the variations to the Assessing Officer; or (b) file his objections, if any, to such variation with,— (i) the Dispute Resolution Panel; and (ii) the Assessing Officer. (3) The Assessing Officer shall complete the assessment on the basis of the draft order, if— (a) the assessee

DCIT, New Delhi vs. M/S Wickwood Development Ltd., New Delhi

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

ITA 3356/DEL/2015[2008-09]Status: DisposedITAT Delhi10 Jan 2024AY 2008-09

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

144C(15)(b) of the Income Tax Act, 1961. The said provision reads as under: “(15) For the purposes of this section,— (a) "Dispute Resolution Panel" means a collegium comprising of three Commissioners of Income-tax constituted by the Board for this purpose; (b) "eligible assessee" means,— (i ) any person ... file his acceptance of the variations to the Assessing Officer; or (b) file his objections, if any, to such variation with,— (i) the Dispute Resolution Panel; and (ii) the Assessing Officer. (3) The Assessing Officer shall complete the assessment on the basis of the draft order, if— (a) the assessee

DCIT, New Delhi vs. M/S. Newbury Holding Two Ltd., New Delhi

ITA 3128/DEL/2015[2010-11]Status: DisposedITAT Delhi10 Jan 2024AY 2010-11

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

Section 153CSection 6(3)(ii)

144C(15)(b) of the Income Tax Act, 1961. The said provision reads as under: “(15) For the purposes of this section, — (a) "Dispute Resolution Panel" means a collegium comprising of three Commissioners of Income-tax constituted by the Board for this purpose; (b) "eligible assessee" means, — (i) any person ... file his acceptance of the variations to the Assessing Officer; or (b) file his objections, if any, to such variation with,— (i) the Dispute Resolution Panel; and (ii) the Assessing Officer. (3) The Assessing Officer shall complete the assessment on the basis of the draft order, if— (a) the assessee