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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

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

In the result, appeal of the assessee (ITA number 1597/M/2018) is allowed for statistical purposes

ITA 374/MUM/2017[2012-13]Status: DisposedITAT Mumbai13 Sept 2023AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shri Narfendrakumar Choudhary , Jm & & The Great Eastern Shipping Co. The Dy. Commissioner Of Ltd. Income-Tax, Kalyaniwalla & Mistry Llp Range-5(3), Esplanade House, 2 N D Floor, Vs. Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Fort, Mumbai-400 001 Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaact1565C The Dy. Commissioner Of Income- The Great Eastern Shipping Co. Tax, Ltd. Range-5(3), Kalyaniwalla & Mistry Llp Vs. Esplanade House, 2 N D Floor, Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Mumbai-400 020 Fort, Mumbai-400 001 (Appellant) (Respondent)

For Appellant: Shri Jeet Kamdar , Shri Falee HFor Respondent: Shri
Section 115Section 14Section 143Section 144C

learned assessing officer pursuant to the order of the learned transfer pricing officer and subject to the direction of the learned dispute resolution panel dated 12/11/2014. 03. Assessee is aggrieved with the same and has preferred this appeal before us raising following grounds of appeal:- Non-Transfer Pricing Issues ... book profit was also enhanced by disallowance under section 14 A of the act. 15. Assessee preferred an objection before the learned dispute resolution panel, directions were passed under section 144C (5) of the act on 12/11/2014. On the ground of the judicial consistency, the dispute resolution panel directed

DCIT 5(3)(2), Mumbai vs. The Great Eastern Shipping Co.Ltd, Mumbai

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3272/MUM/2015[2009-10]Status: DisposedITAT Mumbai13 Sept 2023AY 2009-10

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm The Great Eastern Shipping Co. The Dy. Commissioner Of Ltd. Income-Tax, Kalyaniwalla & Mistry Llp Range-5(3), Esplanade House, 2 Nd Floor, Vs. Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Fort, Mumbai-400 001 Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaact1565C The Dy. Commissioner Of The Great Eastern Shipping Income-Tax, Co. Ltd. Range-5(3), Kalyaniwalla & Mistry Llp Vs. Esplanade House, 2 Nd Floor, Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Mumbai-400 020 Fort, Mumbai-400 001 (Appellant) (Respondent)

For Appellant: Shri Jitendra Jain, AdvocateFor Respondent: Shri Manoj Mishra, CIT DR
Section 115Section 143Section 143(3)Section 144CSection 14A

dated 15/1/2014 by The Deputy Commissioner Of Income Tax Circle 5 (3), Mumbai (The Learned AO) pursuance to the direction issued by The Dispute Resolution Panel – II, Mumbai [ The Ld DRP ] in objection number 95 dated 20/12/2013 in case of draft assessment order passed under section 144C (13) passed ... appeal are raised ITA Nos. 3272/Mum/2015 & 1656/Mum/2014 The Great Eastern Shipping Co. Ltd.; A.Y. 09-10 against the direction of the learned dispute resolution panel :- “On the facts and circumstances of the case and in law, the Hon'ble DRP erred in law in directing that the shipping debts written

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

In the result, appeal of the assessee (ITA number 1597/M/2018) is allowed for statistical purposes

ITA 1216/MUM/2015[2010-11]Status: DisposedITAT Mumbai13 Sept 2023AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Narfendrakumar Choudhary , Jm & & The Great Eastern Shipping Co. The Dy. Commissioner Of Ltd. Income-Tax, Kalyaniwalla & Mistry Llp Range-5(3), Esplanade House, 2 N D Floor, Vs. Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Fort, Mumbai-400 001 Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaact1565C The Dy. Commissioner Of Income- The Great Eastern Shipping Co. Tax, Ltd. Range-5(3), Kalyaniwalla & Mistry Llp Vs. Esplanade House, 2 N D Floor, Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Mumbai-400 020 Fort, Mumbai-400 001 (Appellant) (Respondent)

For Appellant: Shri Jeet Kamdar , Shri Falee HFor Respondent: Shri
Section 115Section 14Section 143Section 144C

learned assessing officer pursuant to the order of the learned transfer pricing officer and subject to the direction of the learned dispute resolution panel dated 12/11/2014. 03. Assessee is aggrieved with the same and has preferred this appeal before us raising following grounds of appeal:- Non-Transfer Pricing Issues ... book profit was also enhanced by disallowance under section 14 A of the act. 15. Assessee preferred an objection before the learned dispute resolution panel, directions were passed under section 144C (5) of the act on 12/11/2014. On the ground of the judicial consistency, the dispute resolution panel directed

The Great Eastern Shipping Co. Ltd, Mumbai vs. DCIT RG 5(3), Mumbai

In the result, appeal filed by the learned assessing officer is dismissed

ITA 1656/MUM/2014[2009-10]Status: DisposedITAT Mumbai13 Sept 2023AY 2009-10

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm The Great Eastern Shipping Co. The Dy. Commissioner Of Ltd. Income-Tax, Kalyaniwalla & Mistry Llp Range-5(3), Esplanade House, 2 Nd Floor, Vs. Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Fort, Mumbai-400 001 Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaact1565C The Dy. Commissioner Of The Great Eastern Shipping Income-Tax, Co. Ltd. Range-5(3), Kalyaniwalla & Mistry Llp Vs. Esplanade House, 2 Nd Floor, Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Mumbai-400 020 Fort, Mumbai-400 001 (Appellant) (Respondent)

For Appellant: Shri Jitendra Jain, AdvocateFor Respondent: Shri Manoj Mishra, CIT DR
Section 115Section 143Section 143(3)Section 144CSection 14A

dated 15/1/2014 by The Deputy Commissioner Of Income Tax Circle 5 (3), Mumbai (The Learned AO) pursuance to the direction issued by The Dispute Resolution Panel – II, Mumbai [ The Ld DRP ] in objection number 95 dated 20/12/2013 in case of draft assessment order passed under section 144C (13) passed ... appeal are raised ITA Nos. 3272/Mum/2015 & 1656/Mum/2014 The Great Eastern Shipping Co. Ltd.; A.Y. 09-10 against the direction of the learned dispute resolution panel :- “On the facts and circumstances of the case and in law, the Hon'ble DRP erred in law in directing that the shipping debts written

Tpg Software Pvt. Ltd., Delhi vs. DCIT, Circle-25(2), New Delhi

In the result, the appeal of the assessee is dismissed

ITA 6468/DEL/2018[2014-15]Status: FixedITAT Delhi11 Sept 2023AY 2014-15

Bench: Sh. Kul Bharatdr. B. R. R. Kumar

For Appellant: Sh. Vishal Kalra, AdvFor Respondent: Sh. Rajesh Kumar, CIT DR
Section 143(3)Section 144C(13)Section 234Section 271(1)(c)Section 92C(3)(c)

regarded as an appropriate comparable for the purpose of benchmarking analysis. 116. The learned departmental representative vehemently supported the order of the learned dispute resolution panel and the learned transfer-pricing officer and submitted that they have discussed the functionality of this company in detail and therefore this company

H&S Software Development and Knowledge Management Centre (P) Ltd, Gurgaon vs. ITO, New Delhi

The appeal of the assessee is allowed in respect of

ITA 516/DEL/2015[2010-11]Status: DisposedITAT Delhi11 Sept 2023AY 2010-11

Bench: SHRI M. BALAGANESH (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)

Section 143(3)

Centre (P) Ltd. vs. ITO (13) of the Income Tax Act, 1961 (hereinafter called ‘the Act’) subsequent to the direction of the Ld. Dispute Resolution Panel (DRP) vide direction dated 23/09/2014 for Asst. Year 2010-11. 2. We find that this appeal was originally disposed off by this Tribunal

M/S Celio Future Fashion Private Limited, Mumbai vs. Addl/Jt/CIT/Dy/Asstt/ITO/NFAC, Delhi

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

ITA 741/MUM/2022[2017-18]Status: DisposedITAT Mumbai08 Sept 2023AY 2017-18

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Sumant ChadhaFor Respondent: Shri Pravin Salunkhe
Section 115BSection 143(3)Section 144BSection 144C(13)Section 144C(5)Section 144C(8)Section 69CSection 920Section 92C

effect Rs.11,67,806. That on the facts and circumstances of the case, learned Assessing Officer (National Faceless Assessment Centre) and Dispute Resolution Panel (DRP) has erred both in law as well on facts in making adjustment M/s. Celio Future Fashion Pvt. Ltd. ITA no.741/Mum./2022 ... this stage, it is relevant to note the provisions of section 144C(8) of the Act, which reads as under:- “(8) The Dispute Resolution Panel may confirm, reduce or enhance the variations proposed in the draft order so, however, that it shall not set aside any proposed variation or issue

Intergreon Munaged Solutions (India) P.Ltd, Mumbai vs. Asst CIT 12(2)(2), Mumbai

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

ITA 586/MUM/2015[2010-11]Status: DisposedITAT Mumbai07 Sept 2023AY 2010-11

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri Ketan Ved
Section 250Section 92D

opted to exercise its option to appeal to the ld. CIT(A) against the impugned addition and not processed before the learned Dispute Resolution Panel ('ld. DRP' for short). Therefore, final assessment order was passed on 22.02.2011. 6. The assessee was in appeal before ... Enterprises (AEs")): (A.Ys.2007-08 & 2010-11) M/s. Integreon Managed Solution (India) Pvt. Ltd. 1.1 The Assessing Officer / the Transfer Pricing Officer / the Dispute Resolution Panel has erred in making an upward adjustment of Rs. 5,56,38,789 to the total income of the Appellant by holding that

Integreon Managed Solutions (India) P. Ltd, Mumbai vs. ITO 8(2)(1), Mumbai

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

ITA 2307/MUM/2012[2007-08]Status: DisposedITAT Mumbai07 Sept 2023AY 2007-08

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri Ketan Ved
Section 250Section 92D

opted to exercise its option to appeal to the ld. CIT(A) against the impugned addition and not processed before the learned Dispute Resolution Panel ('ld. DRP' for short). Therefore, final assessment order was passed on 22.02.2011. 6. The assessee was in appeal before ... Enterprises (AEs")): (A.Ys.2007-08 & 2010-11) M/s. Integreon Managed Solution (India) Pvt. Ltd. 1.1 The Assessing Officer / the Transfer Pricing Officer / the Dispute Resolution Panel has erred in making an upward adjustment of Rs. 5,56,38,789 to the total income of the Appellant by holding that

ITO 8(2)(1), Mumbai vs. Integreon Managed Solution (I) P. Ltd, Mumbai

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

ITA 2095/MUM/2012[2007-08]Status: DisposedITAT Mumbai07 Sept 2023AY 2007-08

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri Ketan Ved
Section 250Section 92D

opted to exercise its option to appeal to the ld. CIT(A) against the impugned addition and not processed before the learned Dispute Resolution Panel ('ld. DRP' for short). Therefore, final assessment order was passed on 22.02.2011. 6. The assessee was in appeal before ... Enterprises (AEs")): (A.Ys.2007-08 & 2010-11) M/s. Integreon Managed Solution (India) Pvt. Ltd. 1.1 The Assessing Officer / the Transfer Pricing Officer / the Dispute Resolution Panel has erred in making an upward adjustment of Rs. 5,56,38,789 to the total income of the Appellant by holding that

Rga International Reinsurance Company Designated Authority Compqny, Mumbai vs. DCIT (International Taxation) 4(1) (1), Mumbai

In the result, appeal filed by the assessee is allowed

ITA 803/MUM/2022[2018-19]Status: DisposedITAT Mumbai06 Sept 2023AY 2018-19

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Rahul Chaudhary, Hon'Ble

Section 143(2)Section 144C(5)

RIFAUR RAHMAN (AM) 1. These appeals are filed by assessee against final assessment order and directions of the Dispute Resolution Panel of Learned Commissioner of Income Tax (DRP-2), Mumbai-1 [hereinafter in short “Ld.DRP”] dated ITA NO. 803 & 2330/MUM/2022 RGA International Reinsurance Company Designated Activity Company ... permanent establishment case of the Assessing Officer, as put to the assessee in the draft assessment order, the assessee raised objection before the Dispute Resolution Panel. It was submitted by the assessee that the assessee does not have any place of business operations in India and that the assessee does

Hireright Ltd, Uk vs. ACIT, Circle 2(1)(1), International Taxation, New Delhi

In the result, the appeals of the assessee for both the AYs 2019-20

ITA 373/DEL/2023[2020-21]Status: DisposedITAT Delhi06 Sept 2023AY 2020-21

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year: 2020-21 & Asstt. Year: 2019-20

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri Vizay B. Vasanta, CIT-DR
Section 143(3)Section 234ASection 234DSection 270A

assessee at Rs. 12,54,69,976/- and Rs. 8,51,94,915/- respectively. 4. The assessee filed objections before the Ld. Dispute Resolution Panel (“DRP”) stating that the aforesaid allegations made by the Ld. AO are grossly incorrect and made the following submissions before

Hireright Limited, London vs. ACIT, Circle 2(1)(1), Int. Tax, New Delhi

In the result, the appeals of the assessee for both the AYs 2019-20

ITA 1884/DEL/2022[2019-20]Status: DisposedITAT Delhi06 Sept 2023AY 2019-20

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year: 2020-21 & Asstt. Year: 2019-20

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri Vizay B. Vasanta, CIT-DR
Section 143(3)Section 234ASection 234DSection 270A

assessee at Rs. 12,54,69,976/- and Rs. 8,51,94,915/- respectively. 4. The assessee filed objections before the Ld. Dispute Resolution Panel (“DRP”) stating that the aforesaid allegations made by the Ld. AO are grossly incorrect and made the following submissions before

DCIT 14 (3)(1), Mumbai vs. Tata Communications Transformation Services Ltd., Mumbai

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

ITA 6240/MUM/2019[2008-09]Status: DisposedITAT Mumbai05 Sept 2023AY 2008-09

Bench: Shri B R Baskaran, Am & Ms. Kavitha Rajagopal, Jm Tata Communications Transformations Dy. Cit (Tp)-4(2)(1) Air India Building, 5Th Floor, Services Limited Vs. D-21/C 36, G Block Bandra Kurla Nariman Point, Mumbai-400 021 Complex, Mumbai-400 008 Pan/Gir No. Aaccv 3189 A (Assessee) : (Revenue) & Dy. Cit-14(3)(1) Tata Communications 4Th Floor, Room No. 455, Aayakar Transformation Services Ltd. Bhavan, M. K. Road, Mumbai-400 020 Plot No. C-21 & C-36 C Tower, Vs. Bkc Vidyanagri Po, Bandra Kurla Complex, Bandra (E), Mumbai-400 098 Pan/Gir No. Aaccv 3189 Q (Revenue) : (Assessee)

For Appellant: Shri Nitesh Joshi
Section 143(1)Section 143(2)Section 143(3)Section 144CSection 2Section 92C

empty formality. When a draft assessment order is passed and copy is given to the Assessee, the Assessee can raise objections before the Dispute Resolution Panel on any of the proposed variations. There is a right given to the Assessee to object, and to have the objections considered ... Assessing Officer, but by the Dispute Resolution Panel. 19. The Tribunal, by order dated 1 October 2012, set aside the entire exercise and the matter was relegated to the Assessing Officer. Once the matter was sent back to be decided afresh it went back to the stage of Section 144C

Tata Communications Transformations Services Limited, Mumbai vs. Dict (Tp)-4(2)(1, Mumbai

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

ITA 5882/MUM/2019[2008-09]Status: DisposedITAT Mumbai05 Sept 2023AY 2008-09

Bench: Shri B R Baskaran, Am & Ms. Kavitha Rajagopal, Jm Tata Communications Transformations Dy. Cit (Tp)-4(2)(1) Air India Building, 5Th Floor, Services Limited Vs. D-21/C 36, G Block Bandra Kurla Nariman Point, Mumbai-400 021 Complex, Mumbai-400 008 Pan/Gir No. Aaccv 3189 A (Assessee) : (Revenue) & Dy. Cit-14(3)(1) Tata Communications 4Th Floor, Room No. 455, Aayakar Transformation Services Ltd. Bhavan, M. K. Road, Mumbai-400 020 Plot No. C-21 & C-36 C Tower, Vs. Bkc Vidyanagri Po, Bandra Kurla Complex, Bandra (E), Mumbai-400 098 Pan/Gir No. Aaccv 3189 Q (Revenue) : (Assessee)

For Appellant: Shri Nitesh Joshi
Section 143(1)Section 143(2)Section 143(3)Section 144CSection 2Section 92C

empty formality. When a draft assessment order is passed and copy is given to the Assessee, the Assessee can raise objections before the Dispute Resolution Panel on any of the proposed variations. There is a right given to the Assessee to object, and to have the objections considered ... Assessing Officer, but by the Dispute Resolution Panel. 19. The Tribunal, by order dated 1 October 2012, set aside the entire exercise and the matter was relegated to the Assessing Officer. Once the matter was sent back to be decided afresh it went back to the stage of Section 144C

Contitech India Pvt. Ltd., New Delhi vs. ACIT, New Delhi

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

ITA 2161/DEL/2017[2012-13]Status: DisposedITAT Delhi05 Sept 2023AY 2012-13

Bench: Sh. Kul Bharatdr. B. R. R. Kumar

For Appellant: NoneFor Respondent: Sh. Sanjay Kr. Bharati, CIT DR
Section 143(3)Section 144Section 37(1)Section 92C

concluding that the appellant has failed to maintain the documents for the purpose of cost analysis. 2.8 That the Dispute Resolution Panel erred on facts and in law in confirming the adjustment made by the TPO with regard to the payment of corporate expense holding that (1) the services rendered ... saving has resulted to the appellant on payment of corporate charges; (iii) the services received by the appellant are generic. 2.9 That the Dispute Resolution Panel erred on facts and in law in holding that the additional evidences filed by the appellant are generic in nature and have little evidentiary

Kellogg India P.Ltd, Mumbai vs. Assistant Commissioner of Income Tax 15(1)(2), Mumbai

In the result, appeal filed by the Assessee stands partly allowed

ITA 2533/MUM/2022[2018-19]Status: DisposedITAT Mumbai31 Aug 2023AY 2018-19

Bench: Shri Br Baskaran, Am & Shri N. K. Choudhry, Jm

For Appellant: Ms. Hirali Desai/ Mr. AmolFor Respondent: Vachaspati Tripathi, Ld. CIT
Section 143(2)Section 144CSection 144C(2)Section 250Section 270ASection 274Section 40Section 92C

Assessee being aggrieved with the Draft assessment order, preferred objections under section 144C(2) of the Act on 26/10/2021 before the Dispute Resolution Panel-1, Mumbai, who vide order dated 07-06-2022 u/s 144C (5) of the Act, decided the objections raised by the Assessee-Company and in para

Imperial Mark Trade (I) P.Ltd, Thane vs. DCIT CC 7(2), Mumbai

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

ITA 1453/MUM/2017[2013-14]Status: DisposedITAT Mumbai31 Aug 2023AY 2013-14

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Ajay R. SinghFor Respondent: Shri Manoj Kumar
Section 143(3)Section 144C(13)Section 144C(5)Section 254(1)Section 92C

read with section 144C(13) of the Income Tax Act, 1961 ("the Act"), pursuant to the directions dated 23/12/2016, issued by the learned Dispute Resolution Panel–1(WZ), Mumbai, [“learned DRP”], under section 144C(5) of the Act, for the assessment year 2013–14. Imperial Mark Trade

Nearbuy Pte.. Ltd, Singapore vs. ACIT (Intl Tax) Circle 3(3) (1), Mumbai

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

ITA 1607/MUM/2022[2018-19]Status: DisposedITAT Mumbai30 Aug 2023AY 2018-19

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

Section 143(3)

Assessing officer for Assessment Year 2018-19 u/s 143(3) r.w.s 144C(13) of the Act in pursuance of directions given by Ld Dispute Resolution Panel (DRP). The solitary issue urged in this appeal relates to the Capital gain computed by the AO as against the capital loss declared

DCIT Cir 3(1)(1), Mumbai vs. Airmid Developers Ltd, Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 949/MUM/2015[2010-11]Status: DisposedITAT Mumbai30 Aug 2023AY 2010-11

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri K. GopalFor Respondent: Shri Manoj Kumar
Section 143(3)Section 144C(13)Section 144C(5)Section 14ASection 271(1)(c)Section 92C

read with section 144C(13) of the Income Tax Act, 1961 (“the Act”), pursuant to the directions issued by the learned Dispute Resolution Panel (“learned DRP”) under section 144C(5) of the Act. IT(TP)A no.6758/Mum./2014 Assessee’s Appeal – A.Y. 2009–10 2. In its appeal, the assessee ... facts and circumstances of the case and in law, the learned Assessing officer (AO) under directions issued by the Hon'ble Dispute Resolution Panel (DRP), erred in making addition of interest expenditure amounting to Rs. 12,923,055/- by reducing Arms Length Price rate from