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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

Rosoboronservice (India) Limited, Mumbai vs. Deputy Commissioner of Income Tax 15(3)(1), Mumbai

In the result, ground number 2 – 6 [ except 4, of the appeal are restored to the file of the learned AO/TPO to benchmark the international transaction afresh by selecting first the A

ITA 7255/MUM/2018[2014-15]Status: DisposedITAT Mumbai12 Oct 2023AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Deputy Commissioner Of Rosoboronservice (India) Limited Income Tax-15(3)(1) R-700, Ttc Industrial Estate, Room No. 473, Aayakar P.O. Ghansoli, Midc Rabale, Vs. Navi Mumbai- 400701 Bhawan, New Marine Lines, Mumbai-400020 (Appellant) (Respondent) Pan No. Aadcr0040B Assessee By : Mr. Gaurav Jain, Advocate Revenue By : Mr. Manoj Kumar, Cit Dr Date Of Hearing: 26.07.2023 Date Of Pronouncement : 12.10.2023

For Appellant: Mr. Gaurav Jain, AdvocateFor Respondent: Mr. Manoj Kumar, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 92(3)Section 92C

r.w.s. 144C(13) of the Income Tax Act, 1961 (The Act) pursuant to direction dated 24.09.2018 issued by The Dispute Resolution Panel, Mumbai (Ld. DRP) dated 24.09.2018 wherein the transfer pricing adjustment proposed by the Ld. TPO u/s 92CA(3) of the Act is incorporated. A.Y.2014-15 M/s Rosoboronservice (India ... read with section 144C(13) of the Income-tax Act, 1961 Act"), pursuant to the directions dated 24 September 2018 by Dispute Resolution Panel. Mumbai ("DRP") u/s 144C(5) of the Act and read with order dated 27 October 2017 issued by Transfer Pricing Officer ("TPO") u/s 92CA

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

In the result, the appeal of the assessee is treated as allowed for statistical purposes subject to the directions contained in para 11, 18 and 19 above

ITA 913/DEL/2023[2020-21]Status: DisposedITAT Delhi12 Oct 2023AY 2020-21

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year: 2020-21

For Appellant: Shri Ravi Sharma, AdvocateFor Respondent: Shri Vizay B. Vasanta, CIT-DR
Section 143(3)Section 144C(13)

Assistant Commissioner of Income-tax, Circle 1(1)(1), International Taxation, New Delhi ("Ld. AO") as well as the Hon'ble Dispute Resolution Panel-1, New Delhi ("DRP") erred in holding that the Appellant has a dependent agent permanent establishment ("PE") in India in terms of Article ... India-Ireland DTAA that was applied by the assessee in its return of income. 4. Aggrieved, the assessee filed objections before the Ld. Dispute Resolution Panel (“DRP”) against the draft assessment order passed by the Ld. AO wherein the Ld. AO proposed to assess the income of the assessee

Thales Six Gts France Sas, Delhi vs. DCIT, 3(1)(1), Delhi

In the result, this appeal is allowed as indicated above

ITA 2380/DEL/2022[2017-18]Status: DisposedITAT Delhi09 Oct 2023AY 2017-18

Bench: Shri Shamim Yahya & Shri Anubhav Sharma[Assessment Year: 2017-18]

Section 119Section 143(3)

dated 28.07.2022 passed u/s 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (hereinafter ‘the Act’) arising out of order of Dispute Resolution Panel dated 20.06.2022 pertaining to AY 2017-18. 2. Although the assessee has raised many grounds. The ld. Counsel for the assessee has prayed ... facts and circumstances of the case and in law, in the absence of Document Identification Number (DIN) on the directions issued by the Dispute Resolution Panel (“DRP”) in compliance of CBDT Circular No.19/2019, such directions and consequent final assessment order dated July 28, 2022 are bad in law, void

Delphi Automotive Systems (P) Ltd, New Delhi vs. Deputy Commissioner of Income-Tax, New Delhi

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

ITA 1361/DEL/2015[2010-11]Status: DisposedITAT Delhi09 Oct 2023AY 2010-11

Bench: Shri M. Balaganesh & Shri Anubhav Sharmaaptive Components India P. Ltd, Vs. Deputy Commissioner (Formerly Known As Delphi Of Income-Tax, Automotive Systems P. Ltd), Circle-7(1), P-24, Green Park Extension, New Delhi South Delhi, New Delhi-110016 (Appellant) (Respondent) Pan:Aaacd0226E

For Appellant: Sh. Neeraj Jain, AdvFor Respondent: Sh. Rajesh Kumar, CIT DR
Section 143(3)Section 144CSection 92CSection 92C(2)

services on the basis of order passed by the Transfer Pricing Officer (TPO) under section 92CA(3) of the Act. 2.1 That the Dispute Resolution Panel (DRP) erred on facts and in law in sustaining the action of the TPO in considering following companies in the final set of comparable

Indium IV (Mauritius) Holdings Limited, Mumbai vs. Deputy Comm. of Income Tax (International Taxation) 2(2)(1), Mumbai

In the result, appeal filed by the assessee is allowed

ITA 2423/MUM/2022[2017-18]Status: DisposedITAT Mumbai06 Oct 2023AY 2017-18

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bleindium Iv (Mauritius) Holdings Limited V. Dcit (International Transaction)-2(2)(1) Office 201, 2Nd Floor, Sterling Tower Room No. 1722, 17Th Floor Air India Building, Nariman Point 14 Poudriere Street, Port Louis Mumbai – 400 021 Mauritius Pan: Aacci4907P (Appellant) (Respondent)

Section 143(2)Section 144C(5)Section 2(24)Section 45Section 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 Commissioner of Income Tax (DRP-1), Mumbai [hereinafter in short Indium IV (Mauritius) Holdings Limited “Ld.DRP”] dated 14.06.2022 for the A.Y.2017-18 passed u/s.144C

Jaguar Land Rover India Ltd., Mumbai vs. Addl/Jt./Dy/CIT/Asstt/ITO, National E-Assessment Centre, Delhi

In the result, appeal of the assessee is allowed

ITA 1222/MUM/2021[2016-17]Status: DisposedITAT Mumbai06 Oct 2023AY 2016-17
Section 143(2)Section 143(3)Section 40Section 40aSection 92C

shall and equated to limitation especially when further proceedings are contemplated under the Act such as passing draft assessment order, remedy before Dispute resolution panel and final assessment order. viii. There is no necessity or occasion to read the word "may" as "shall" Sub-sections 3A and 4 were introduced ... option either to file his acceptance of the variation of the assessment or file his objection to any such variation with the Dispute Resolution Panel and also the Assessing Officer. Sub-section (5) of section 144C of the Act provides that if any objections are raised by the assessee before

Jubilant Foodworks Ltd., Noida vs. DCIT, Circle-1, Noida

In the result, appeal is partly allowed

ITA 7937/DEL/2018[2014-15]Status: DisposedITAT Delhi06 Oct 2023AY 2014-15

Bench: Shri Saktijit Dey, Vice- & Shri M. Balaganeshassessment Year: 2014-15 Jubilant Foodworks Ltd., Versus Dcit, Circle-1, Plot No. 1A, Sector-16A, Noida. Noida. Pan: Aabcd1821C (Appellant) (Respondent) Assessee By : Sh. Ajay Vohra, Sr. Advocate Sh. K.M. Gupta, Advocate Sh. Shruti Khimta, A.R. Revenue By : Sh. Rajesh Kumar, Cit-Dr

For Appellant: Sh. Ajay Vohra, Sr. AdvocateFor Respondent: Sh. Rajesh Kumar, CIT-DR
Section 143(3)Section 92A

/92CA(3)/144C(5) of the Income-tax Act, 1961 pertaining to assessment year 2014-15, in pursuance to directions of learned Dispute Resolution Panel (DRP). 2 2. In addition to main grounds, vide letter dated 16.09.2021, the assessee has raised an additional ground, being ground

Strides Pharma Science Ltd., Navi Mumbai vs. The Dy CIT -5(1)(2), Mumbai

In the result ITA number 1004/M/2021 filed by the assessee for assessment year 2016 – 17 is allowed

ITA 1004/MUM/2021[2016-17]Status: DisposedITAT Mumbai05 Oct 2023AY 2016-17

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Strides Pharma Science Ltd. Dcit 15(1)(2) 201, Devavrata, Sector-17, Aayakar Bhavan, M K Road, Vs. Vashi, Navi Mumbai, 400703 Mumbai 400020 (Appellant) (Respondent) Pan No. Aadcs8104P

For Respondent: Ms Samruddhi Hande SR DR
Section 143(3)Section 14ASection 92C

Pharma Science Ltd. I Transfer Pricing 1 The learned Assessing Officer ("AD"), the learned Transfer Pricing Officer (“TPO”) and the Honorable ("Hon'ble) Dispute Resolution Panel (“DRP”) erred in making adjustment under section 92CA of the Act amounting to INR 9,5,.43,090, details of which are provided below ... financing. Assessee submitted that it has not charged interest on advances from non-associated enterprises as well. It further stated that the learned Dispute Resolution Panel for assessment year 2014 – 15, 13 – 14 and 11 – 12 has deleted the similar adjustment made by the TPO with respect to the export

M/S. Atul Projects India P Ltd, Mumbai vs. DCIT- 9(1)(2) (Now Juridiction With Dc CC 2(4)), Mumbai

ITA 1940/MUM/2023[2014-15]Status: DisposedITAT Mumbai27 Sept 2023AY 2014-15

Bench: Ms. Kavitha Rajagopal () & Ms. Padmavathy S. ()

Section 132Section 143(2)Section 14ASection 153CSection 37(1)Section 43CSection 69CSection 80I

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 20-9-2019. 15 I.T.A. No.1940,1876,1877, 1879 & 1880 / Mum/2023 M/s Atul Projects India Pvt Ltd 16. The final

M/S. Atul Projects India Pvt Ltd., Mumbai vs. DCIT- 9(1)(2), ( Now Juridiction With Dc CC-2(4), Mumbai

ITA 1880/MUM/2023[2019-20]Status: DisposedITAT Mumbai27 Sept 2023AY 2019-20

Bench: Ms. Kavitha Rajagopal () & Ms. Padmavathy S. ()

Section 132Section 143(2)Section 14ASection 153CSection 37(1)Section 43CSection 69CSection 80I

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 20-9-2019. 15 I.T.A. No.1940,1876,1877, 1879 & 1880 / Mum/2023 M/s Atul Projects India Pvt Ltd 16. The final

M/S. Atul Projects India Pvt Ltd., Mumbai vs. DCIT- 9(1)(2), ( Now Juridiction With Dc CC-2(4), Mumbai

ITA 1879/MUM/2023[2017-18]Status: DisposedITAT Mumbai27 Sept 2023AY 2017-18

Bench: Ms. Kavitha Rajagopal () & Ms. Padmavathy S. ()

Section 132Section 143(2)Section 14ASection 153CSection 37(1)Section 43CSection 69CSection 80I

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 20-9-2019. 15 I.T.A. No.1940,1876,1877, 1879 & 1880 / Mum/2023 M/s Atul Projects India Pvt Ltd 16. The final

M/S. Atul Projects India Pvt Ltd., Mimbai vs. DCIT- 9(1)(2), ( Now Juridiction With Dc CC-2(4), Mumbai

ITA 1877/MUM/2023[2016-17]Status: DisposedITAT Mumbai27 Sept 2023AY 2016-17

Bench: Ms. Kavitha Rajagopal () & Ms. Padmavathy S. ()

Section 132Section 143(2)Section 14ASection 153CSection 37(1)Section 43CSection 69CSection 80I

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 20-9-2019. 15 I.T.A. No.1940,1876,1877, 1879 & 1880 / Mum/2023 M/s Atul Projects India Pvt Ltd 16. The final

M/S. Atul Projects India Pvt Ltd., Mumbai vs. DCIT- 9(1)(2), ( Now Juridiction With Dc CC-2(4), Mumbai

ITA 1876/MUM/2023[2015-16]Status: DisposedITAT Mumbai27 Sept 2023AY 2015-16

Bench: Ms. Kavitha Rajagopal () & Ms. Padmavathy S. ()

Section 132Section 143(2)Section 14ASection 153CSection 37(1)Section 43CSection 69CSection 80I

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 20-9-2019. 15 I.T.A. No.1940,1876,1877, 1879 & 1880 / Mum/2023 M/s Atul Projects India Pvt Ltd 16. The final

M/S. Buro Happold Ltd, Mumbai vs. Dy.CIT (Int Tax) -1(3) (2), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 516/MUM/2022[2018-19]Status: DisposedITAT Mumbai27 Sept 2023AY 2018-19

Bench: Shri Vikas Awasthy& Ms. Padmavathy.Sआअसं.516/मुं/2022 (िन.व. 2018-19) Buro Happold Limited, C/O. Sudit K. Parekh & Co. Llp, Urmix Axis, 06Th Floor, Famous Studio Lane, Dr.E.Moses Road, Mahalaxmi, Mumbai 400 011. Pan: Aabcb-9239-Q ...... अपीलाथ"/Appellant बनाम Vs. Deputy Commissioner Of Income Tax International Taxation -1(3)(2),Mumbai 1810, 18Th Floor, Air India Building, Nariman Point, Mumbai 400 021. ..... "ितवादी/Respondent अपीलाथ" "ारा /Appellant By : Shri Vijay Mehta "ितवादी "ारा /Respondent By : Shri Anil Sant सुनवाई की ितिथ/ Date Of Hearing : 10/08/2023 घोषणा की ितिथ/ Date Of Pronouncement : 27/09/2023 आदेश/Order Per Vikas Awasthy, Jm:

For Appellant: Shri Vijay MehtaFor Respondent: Shri Anil Sant
Section 143(3)Section 234BSection 234C

Fees for technical services (FTS) 1.1 On the facts and in the circumstances of the case and in law, the learned DRP ('Dispute Resolution Panel') and DCIT have erred in considering income from consulting and engineering services amounting to INR 21,25,145/- as Fees for technical services ... Royalty and Fees technical services (FTS) 2.1 On the facts and in the circumstances of the case and in law, the learned DRP ('Dispute Resolution Panel'} and DCIT have erred in considering common cost recharge amounting to INR 4,72,39,386/- as Royalty and Fees for technical services

Kraft Foods Group Brands Llc, Mumbai vs. Assistant Commissioner of Income Tax (International Taxation)-3(1)(2), Mumbai

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

ITA 2495/MUM/2022[2019-20]Status: DisposedITAT Mumbai27 Sept 2023AY 2019-20

Bench: Us Raising Following Grounds In Its Appeal: -

Section 143(2)Section 144C(5)Section 153Section 234BSection 270ASection 9(1)(vii)

RIFAUR RAHMAN (AM) 1. This appeal is filed by the assessee against final Assessment Order and directions of the Dispute Resolution Panel of Learned Commissioner of Income Tax (DRP-1), Mumbai-2 [hereinafter in short “Ld.DRP”] dated 07.06.2022 for the A.Y.2019-20 passed u/s. 144C(5) of Income

Shri Ravi Ramakrishnan, Mumbai vs. International Tax Ward 4(1)(1), Mumbai

The appeal of the assessee is allowed for statistical purpose in the terms aforesaid directions

ITA 646/MUM/2023[2014-15]Status: DisposedITAT Mumbai26 Sept 2023AY 2014-15

Bench: Shri Vikas Awasthy & Shri Gagan Goyalआअसं.646/मुं/2023 (िन.व.2014-15) Ravi Ramakrishnan, 205/404, Khar Rose Minar Building, 4Th Floor, 10Th Road, Khar (West, Mumbai 400 052 Pan: Anwpr-2793-J ...... अपीलाथ" /Appellant बनाम Vs. International Tax Ward 4(1)(1), Room No.1729, 17Th Floor, Air India Building, Nariman Point, Mumbai – 400 021. ..... "ितवादी/Respondent अपीलाथ" "ारा/ Appellant By : Ms. Anushree Gupta "ितवादी "ारा/Respondent By : Shri Anil Sant सुनवाई क" ितिथ/ Date Of Hearing : 26/09/2023 घोषणा क" ितिथ/ Date Of Pronouncement : 26/09/2023 आदेश आदेश/ Order आदेश आदेश Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Assessment Order Dated 10/01/2023 Passed U/S. 147 R.W.S. 144C(13) Of The Income Tax Act, 1961 [ In Short ‘The Act], For Assessment Year 2014-15. 2. The Assessee Has Raised Following Grounds In Appeal: “ The Following Grounds Are Independent Of & Without Prejudice To One Another: 1. On The Facts & Circumstances Of The Case & In The Law, The Final Assessment Order Passed By The Learned Assessing Officer ('Ld. Ao') Under Section 147 R.W.S. 144C(13) / Directions Passed By The Hon'Ble Dispute Resolution Panel ('Drp') Under 2 Section 144C(5) Of The Income-Tax Act, 1961 ('The Act1) Is Bad, Both In The Eye Of Law & On The Facts On Account Of:

For Appellant: Ms. Anushree GuptaFor Respondent: Shri Anil Sant
Section 144C(5)Section 147Section 49(4)Section 56(2)(vii)

final assessment order passed by the Learned Assessing Officer ('Ld. AO') under section 147 r.w.s. 144C(13) / Directions passed by the Hon'ble Dispute Resolution Panel ('DRP') under 2 section 144C(5) of the Income-tax Act, 1961 ('the Act1) is bad, both ... Anushree Gupta appearing on behalf of the assessee submitted at the outset that the assessee has filed an application before the Dispute Resolution Panel(DRP) under Rule 13 of Income Tax (Dispute Resolution Panel) Rules, 2009 for rectification of the Directions on 23/12/2022. If the aforesaid application is allowed

Softwareone Pte. Ltd., Singapore vs. ACIT, Circle-3(1)(2) Int.Taxation, New Delhi

In the result, appeals are allowed as indicated above

ITA 1840/DEL/2022[2019-20]Status: DisposedITAT Delhi25 Sept 2023AY 2019-20

Bench: Shri Saktijit Dey, Vice- & Dr. Brr Kumar

For Appellant: Ms. Ananya Kapoor, AdvFor Respondent: Sh. Vizay B. Vasanta, CIT-DR
Section 143(3)Section 144C(13)

Income-tax Act, 1961, pertaining to assessment years 2018-19 and 2019-20, in pursuance to the directions of learned Dispute Resolution Panel (DRP). 2. The only common dispute arising in these appeals relates to taxability of the amount received from sale of software as fees for technical services

Softwareone Pte.Ltd., Singapore vs. ACIT, Circle-3(1)(2) Int.Taxation, Delhi

In the result, appeals are allowed as indicated above

ITA 1839/DEL/2022[2018-19]Status: DisposedITAT Delhi25 Sept 2023AY 2018-19

Bench: Shri Saktijit Dey, Vice- & Dr. Brr Kumar

For Appellant: Ms. Ananya Kapoor, AdvFor Respondent: Sh. Vizay B. Vasanta, CIT-DR
Section 143(3)Section 144C(13)

Income-tax Act, 1961, pertaining to assessment years 2018-19 and 2019-20, in pursuance to the directions of learned Dispute Resolution Panel (DRP). 2. The only common dispute arising in these appeals relates to taxability of the amount received from sale of software as fees for technical services

Goto Technologies Ireland Unlimited Company (Formely Known As Logmeln Ireland Unlimited Company), Dublin vs. ACIT Circle International Taxation 2(2)(1), New Delhi

In the result, appeals are allowed

ITA 1514/DEL/2022[2019-20]Status: DisposedITAT Delhi25 Sept 2023AY 2019-20

Bench: Shri Saktijit Dey, Vice- & Dr. Brr Kumarassessment Year: 2019-20 Goto Technologies Ireland Versus Acit, Circle 2(2)(1) Unlimited Company(Formerly International Taxation, Known As Logmein Ireland New Delhi. Unlimited Company), Dublin. Pan: Aaccl4273H (Appellant) (Respondent) Assessment Year: 2020-21 Goto Technologies Ireland Versus Acit, Circle 1(3)(1) Unlimited Company(Formerly International Taxation, Known As Logmein Ireland New Delhi. Unlimited Company),Ireland. Pan: Aaccl4273H (Appellant) (Respondent)

For Appellant: Sh. Chavali Narayan, CAFor Respondent: Sh. Vizay B. Vasanta, CIT-DR
Section 143(3)Section 144C(13)

Income-tax Act, 1961 pertaining to assessment years 2019-20 and 2020-21, in pursuance to the directions of learned Dispute Resolution Panel (DRP). 2. At the outset, learned counsel appearing for the assessee submitted that the additional grounds raised in assessment year 2019- 20, on instructions

Little Fairy Limited, Nicosia vs. ACIT, Circle Int. Tax. 2(2)(1), Delhi

In the result both the appeals of the assessee are allowed as indicated above

ITA 1512/DEL/2022[2016-17]Status: DisposedITAT Delhi25 Sept 2023AY 2016-17

Bench: Shri G. S. Pannua N D Shri Challa Nagendra Prasad

For Appellant: Shri G. C. Srivastava

assessee but this amendment may take effect from 01.04.2020. The relevant part of the Finance Bills reads as under: “Amendment in Dispute Resolution Panel (DRP). Section 144C of the Act provides that in case of certain eligible assessees, viz., foreign companies and any person in whose case transfer pricing adjustments