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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

Adobe Systems Software Ireland Ltd, Ireland vs. ACIT, Circle 1(1)(1), International Taxation, New Delhi

Appeal is allowed in terms indicate above

ITA 804/DEL/2023[2016-17]Status: DisposedITAT Delhi22 Dec 2023AY 2016-17

Bench: Shri Shamim Yahya & Shri Kul Bharat[Assessment Year : 2016-17] Adobe Systems Software Ireland Vs Acit, Ltd., 406, Riverwalk, Citywest Circle-1(1)(1), Business Campus, Saggart, International Dublin 24, Ireland Taxation, Pan-Aahca7203M New Delhi. Appellant Respondent Appellant By Shri Ravi Sharma, Adv. & Ms. Shruti Khimta, Ar Respondent By Shri Vizay B.Vasanta, Cit Dr Date Of Hearing 12.12.2023 Date Of Pronouncement 22.12.2023 Order Per Kul Bharat, Jm : The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By Ld.Acit, Circle-International Taxation 1(1)(1), Delhi Dated 24.01.2023 For The Assessment Year 2016-17. 2. The Assessee Has Raised Following Grounds Of Appeal:-

Assistant Commissioner of Income-tax, Circle 1(1)(1), International Taxation, New Delhi ("Ld. AO") as well as the Hon'ble Dispute Resolution Panel I, New Delhi (DRP) erred in holding that the Appellant has a dependent agent permanent establishment ("PE") in India in terms of Article ... therefore, passed a draft assessment order u/s 144C of the Income Tax Act, 1961 (“the Act”). The assessee field its objection before Ld. Dispute Resolution Panel (“DRP”) who disposed off the objections vide direction dated 14.11.2022. Thereafter, the AO passed a final assessment order dated 24.01.2023 thereby, he assessed

Bently Nevada Llc, United States vs. Dcitcircle1(1)(2)International Taxation, New Delhi

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

ITA 3384/DEL/2023[2021-22]Status: DisposedITAT Delhi22 Dec 2023AY 2021-22

Bench: Shri Shamim Yahya & Ms. Astha Chandrastay Application No.436/Del/2023 (In Ita No.3384/Del/2023) (Assessment Year: 2021-22) & Bently Nevada Llc, Vs. Dcit, Circle 1(1), C/O 6Th Floor, Building No.71, International Taxation, Standard Chartered Building, New Delhi. Dlf Cyber City Phase Iii, Gurgaon – 122 002 (Haryana).

For Appellant: Shri Sachit Jolly, AdvocateFor Respondent: Shri Vijay B. Vasanta, CIT DR
Section 119Section 131Section 133

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. 16. The final assessment order was passed by the Assessing Officer (AO) on 15.10.2019, under Section 147/144

Arkha Solar Power Private Limited, Rajahmundary vs. DCIT-1, Kakinada

In the result, appeal of the assessee is allowed

ITA 92/VIZ/2022[2017-2018]Status: DisposedITAT Visakhapatnam22 Dec 2023AY 2017-2018

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble(Through Hybrid Hearing) आयकरअपीलसं./ I.T.A. No.92/Viz/2022 ("नधा"रणवष"/ Assessment Year : 2017-18) Arkha Solar Power Private Vs. Deputy Commissioner Of Limited, Income Tax-1, Elakolanu Village, 4Th Floor, Sri Deepthi Towers, Rangampeta, Rajahmundry, Main Road, Kakinada, Andhra Pradesh – 533294. Andhra Pradesh-533001. Pan: Aalca 4293K (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Assessee By : Ms. Karishma R. Phatarphekar ""याथ"क"ओरसे/ Revenue By : Dr. Satyasai Rath, Cit-Dr

For Appellant: Ms. Karishma R. PhatarphekarFor Respondent: Dr. Satyasai Rath, CIT-DR
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 92C(1)

vide DIN and Order No. ITBA/AST/F/144C/2021-22/1032686293(1), dated 26/04/2021. Aggrieved by the Draft Assessment Order, the assessee raised its objections before the Ld. Dispute Resolution Panel [DRP]. The Ld. DRP considering the objections raised by the assessee observed that the NCDs are issued to the controlling entity of the assessee

Hcl Technologies Italy S.P.A, Italy vs. ACIT Circle -2(1)(1) International Taxation, New Delhi

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

ITA 596/DEL/2021[2012-13]Status: DisposedITAT Delhi20 Dec 2023AY 2012-13

Bench: SHRI KUL BHARAT (Judicial Member), SHRI M. BALAGANESH (Accountant Member)

Section 144C(13)

also under the Double Taxation Avoidance Agreement (DTAA). The assessee filed objections before the Dispute Resolution Panel (DRP) and the same were disposed of by the DRP vide its directions dated 8.3.2021 giving partial relief to the assessee. Pursuant to the directions of the ld. DRP, the ld. AO passed

Hcl Technologies Belgium Bvba, New Delhi vs. ACIT Circle -2(1)(1) International Taxation, New Delhi

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

ITA 595/DEL/2021[2012-13]Status: DisposedITAT Delhi20 Dec 2023AY 2012-13

Bench: SHRI KUL BHARAT (Judicial Member), SHRI M. BALAGANESH (Accountant Member)

Section 144C(13)

also under the Double Taxation Avoidance Agreement (DTAA). The assessee filed objections before the Dispute Resolution Panel (DRP) and the same were disposed of by the DRP vide its directions dated 8.3.2021 giving partial relief to the assessee. Pursuant to the directions of the ld. DRP, the ld. AO passed

Hcl Mexico S. De R L, Mexico vs. ACIT Circle -2(1)(1) International Taxation, New Delhi

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

ITA 594/DEL/2021[2012-13]Status: DisposedITAT Delhi20 Dec 2023AY 2012-13

Bench: SHRI KUL BHARAT (Judicial Member), SHRI M. BALAGANESH (Accountant Member)

Section 144C(13)

also under the Double Taxation Avoidance Agreement (DTAA). The assessee filed objections before the Dispute Resolution Panel (DRP) and the same were disposed of by the DRP vide its directions dated 8.3.2021 giving partial relief to the assessee. Pursuant to the directions of the ld. DRP, the ld. AO passed

Hcl Hongkong Sar Limited, New Delhi vs. ACIT Circle -2(1)(1) International Taxation, New Delhi

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

ITA 593/DEL/2021[2012-13]Status: DisposedITAT Delhi20 Dec 2023AY 2012-13

Bench: SHRI KUL BHARAT (Judicial Member), SHRI M. BALAGANESH (Accountant Member)

Section 144C(13)

also under the Double Taxation Avoidance Agreement (DTAA). The assessee filed objections before the Dispute Resolution Panel (DRP) and the same were disposed of by the DRP vide its directions dated 8.3.2021 giving partial relief to the assessee. Pursuant to the directions of the ld. DRP, the ld. AO passed

Hcl Technologies (Proprietary) Limited, New Delhi vs. ACIT Circle -2(1)(1) International Taxation, New Delhi

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

ITA 567/DEL/2021[2012-13]Status: DisposedITAT Delhi20 Dec 2023AY 2012-13

Bench: SHRI KUL BHARAT (Judicial Member), SHRI M. BALAGANESH (Accountant Member)

Section 144C(13)

also under the Double Taxation Avoidance Agreement (DTAA). The assessee filed objections before the Dispute Resolution Panel (DRP) and the same were disposed of by the DRP vide its directions dated 8.3.2021 giving partial relief to the assessee. Pursuant to the directions of the ld. DRP, the ld. AO passed

Hcl Technologies Bv, Netherlands vs. ACIT Circle -2(1)(1) International Taxation, New Delhi

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

ITA 565/DEL/2021[2012-13]Status: DisposedITAT Delhi20 Dec 2023AY 2012-13

Bench: SHRI KUL BHARAT (Judicial Member), SHRI M. BALAGANESH (Accountant Member)

Section 144C(13)

also under the Double Taxation Avoidance Agreement (DTAA). The assessee filed objections before the Dispute Resolution Panel (DRP) and the same were disposed of by the DRP vide its directions dated 8.3.2021 giving partial relief to the assessee. Pursuant to the directions of the ld. DRP, the ld. AO passed

Hcl Australia Services Pty Ltd, Australia vs. ACIT Circle -2(1)(1) International Taxation, New Delhi

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

ITA 564/DEL/2021[2012-13]Status: DisposedITAT Delhi20 Dec 2023AY 2012-13

Bench: SHRI KUL BHARAT (Judicial Member), SHRI M. BALAGANESH (Accountant Member)

Section 144C(13)

also under the Double Taxation Avoidance Agreement (DTAA). The assessee filed objections before the Dispute Resolution Panel (DRP) and the same were disposed of by the DRP vide its directions dated 8.3.2021 giving partial relief to the assessee. Pursuant to the directions of the ld. DRP, the ld. AO passed

Hcl Technologies Maylasia Sdn Bhd, Malaysia vs. ACIT Circle -2(1)(1) International Taxation, New Delhi

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

ITA 563/DEL/2021[2012-13]Status: DisposedITAT Delhi20 Dec 2023AY 2012-13

Bench: SHRI KUL BHARAT (Judicial Member), SHRI M. BALAGANESH (Accountant Member)

Section 144C(13)

also under the Double Taxation Avoidance Agreement (DTAA). The assessee filed objections before the Dispute Resolution Panel (DRP) and the same were disposed of by the DRP vide its directions dated 8.3.2021 giving partial relief to the assessee. Pursuant to the directions of the ld. DRP, the ld. AO passed

Hcl (Brazil) Technologies Da Informacao Eireli, New Delhi vs. ACIT Circle -2(1)(1) International Taxation, New Delhi

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

ITA 562/DEL/2021[2012-13]Status: DisposedITAT Delhi20 Dec 2023AY 2012-13

Bench: SHRI KUL BHARAT (Judicial Member), SHRI M. BALAGANESH (Accountant Member)

Section 144C(13)

also under the Double Taxation Avoidance Agreement (DTAA). The assessee filed objections before the Dispute Resolution Panel (DRP) and the same were disposed of by the DRP vide its directions dated 8.3.2021 giving partial relief to the assessee. Pursuant to the directions of the ld. DRP, the ld. AO passed

Hcl Canada Inc., Canada vs. ACIT Circle -2(1)(1) International Taxation, New Delhi

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

ITA 561/DEL/2021[2012-13]Status: DisposedITAT Delhi20 Dec 2023AY 2012-13

Bench: SHRI KUL BHARAT (Judicial Member), SHRI M. BALAGANESH (Accountant Member)

Section 144C(13)

also under the Double Taxation Avoidance Agreement (DTAA). The assessee filed objections before the Dispute Resolution Panel (DRP) and the same were disposed of by the DRP vide its directions dated 8.3.2021 giving partial relief to the assessee. Pursuant to the directions of the ld. DRP, the ld. AO passed

Hcl Poland Sp Zoo, Poland vs. ACIT Circle -2(1)(1) International Taxation, New Delhi

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

ITA 560/DEL/2021[2012-13]Status: DisposedITAT Delhi20 Dec 2023AY 2012-13

Bench: SHRI KUL BHARAT (Judicial Member), SHRI M. BALAGANESH (Accountant Member)

Section 144C(13)

also under the Double Taxation Avoidance Agreement (DTAA). The assessee filed objections before the Dispute Resolution Panel (DRP) and the same were disposed of by the DRP vide its directions dated 8.3.2021 giving partial relief to the assessee. Pursuant to the directions of the ld. DRP, the ld. AO passed

Hcl Technologies Germany Gmbh, Germany vs. ACIT Circle -2(1)(1) International Taxation, New Delhi

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

ITA 559/DEL/2021[2012-13]Status: DisposedITAT Delhi20 Dec 2023AY 2012-13

Bench: SHRI KUL BHARAT (Judicial Member), SHRI M. BALAGANESH (Accountant Member)

Section 144C(13)

also under the Double Taxation Avoidance Agreement (DTAA). The assessee filed objections before the Dispute Resolution Panel (DRP) and the same were disposed of by the DRP vide its directions dated 8.3.2021 giving partial relief to the assessee. Pursuant to the directions of the ld. DRP, the ld. AO passed

Hcl Technologies France, New Delhi vs. ACIT, Circle-Int. Tax 2(1)(1), New Delhi

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

ITA 544/DEL/2021[2012-13]Status: DisposedITAT Delhi20 Dec 2023AY 2012-13

Bench: SHRI KUL BHARAT (Judicial Member), SHRI M. BALAGANESH (Accountant Member)

Section 144C(13)

also under the Double Taxation Avoidance Agreement (DTAA). The assessee filed objections before the Dispute Resolution Panel (DRP) and the same were disposed of by the DRP vide its directions dated 8.3.2021 giving partial relief to the assessee. Pursuant to the directions of the ld. DRP, the ld. AO passed

Hcl Technologies Philippines Inc., New Delhi vs. ACIT, Circle-Int. Tax 2(1)(1), New Delhi

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

ITA 543/DEL/2021[2012-13]Status: DisposedITAT Delhi20 Dec 2023AY 2012-13

Bench: SHRI KUL BHARAT (Judicial Member), SHRI M. BALAGANESH (Accountant Member)

Section 144C(13)

also under the Double Taxation Avoidance Agreement (DTAA). The assessee filed objections before the Dispute Resolution Panel (DRP) and the same were disposed of by the DRP vide its directions dated 8.3.2021 giving partial relief to the assessee. Pursuant to the directions of the ld. DRP, the ld. AO passed

Hcl Singapore Pte Ltd, New Delhi vs. ACIT Circle International Taxation 2(1)(1), New Delhi

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

ITA 537/DEL/2021[2012-13]Status: DisposedITAT Delhi20 Dec 2023AY 2012-13

Bench: SHRI KUL BHARAT (Judicial Member), SHRI M. BALAGANESH (Accountant Member)

Section 144C(13)

also under the Double Taxation Avoidance Agreement (DTAA). The assessee filed objections before the Dispute Resolution Panel (DRP) and the same were disposed of by the DRP vide its directions dated 8.3.2021 giving partial relief to the assessee. Pursuant to the directions of the ld. DRP, the ld. AO passed

Hcl Technologies Denmark Aps, New Delhi vs. ACIT Circle- 2(1)(1) International Taxation, New Delhi

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

ITA 528/DEL/2021[2012-13]Status: DisposedITAT Delhi20 Dec 2023AY 2012-13

Bench: SHRI KUL BHARAT (Judicial Member), SHRI M. BALAGANESH (Accountant Member)

Section 144C(13)

also under the Double Taxation Avoidance Agreement (DTAA). The assessee filed objections before the Dispute Resolution Panel (DRP) and the same were disposed of by the DRP vide its directions dated 8.3.2021 giving partial relief to the assessee. Pursuant to the directions of the ld. DRP, the ld. AO passed

Hewitt Associates (India) Pvt. Ltd., Gurgaon vs. DCIT, New Delhi

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

ITA 5418/DEL/2012[2008-09]Status: HeardITAT Delhi20 Dec 2023AY 2008-09

Bench: Sh. N. K. Billaiya & Sh. Anubhav Sharmaassessment Year: 2008-09 Hewitt Associates (India) Vs. Dcit Pvt. Ltd. Hewitt Tower, Circle – 10 (1) Sector-42, Dlf City, New Delhi Gurgaon Haryana Pan No.Aabch1559D (Appellant) (Respondent) Appellant By Sh. Ajit Jain, Ca Sh. Arpan Khanna, Ca Sh. Piyush Aggarwal, Ca Respondent By Sh. Rajesh Kumar Cit Dr Date Of Hearing: 15/12/2023 Date Of Pronouncement: 20/12/2023 Order

Section 10ASection 133(6)Section 143Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 92CSection 92F

accordance with the law and therefore not sustainable. Transfer Pricing ("TP") Adjustment - INR 22,648,798 That the Hon'ble Dispute Resolution Panel (DRP), New Delhi has erred both in law and on facts by summarily rejecting the Appellant's objections to the draft order dated November 24, 2011 passed