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“directions of the DRP”

Assessment ProceduresSection 144CSection 144C1,202 judgments

The decision most relied on for directions of the DRP is Commissioner of Income Tax v. Roca Bathroom Products (P) ltd. (445 ITR 537), cited in 269 judgments on BharatTax.

Leading authorities on directions of the DRP

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).

Vijay Television (P.) Ltd. v. DRP
369 ITR 113 · 2014 · High Court
140
citing judgments

Passing a final assessment order under Section 143(3) directly, without first issuing a draft assessment order under Section 144C(1) for an eligible assessee, constitutes a fundamental jurisdictional defect. This defect cannot be cured by a subsequent corrigendum, especially if issued beyond the prescribed period of limitation.

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.

Capital IQ Information Systems India Pvt. Ltd. v. DCIT
32 Taxmann.com 21 · 2013 · ITAT
44
citing judgments

A change in depreciation policy impacts an entity's profitability, which is a key factor in assessing its suitability as a comparable company for transfer pricing analysis.

Shelf Drilling Ron Tappmeyer Ltd. v. ACIT (International Taxation)
457 ITR 161 · 2023 · High Court
30
citing judgments

The limitation period for passing an assessment order under Section 153 of the Income Tax Act prevails over the specific time restriction for passing a final order under Section 144C(13).

Software Paradigms Infotech (P.) Ltd. v. ACIT
89 Taxmann.com 339 · 2018 · ITAT
17
citing judgments

An assessment order passed without giving effect to the binding directions of the Dispute Resolution Panel (DRP) under section 144C(10) within the stipulated time under section 144C(13) is null and void and must be set aside.

Bombay and Delhi High Courts in Vodafone Idea Limited v. Central Processing Centre
459 ITR 413 · 2023 · High Court
15
citing judgments

When determining the date of receipt of Directions from the Dispute Resolution Panel (DRP) by the Assessing Officer (AO) for the purpose of limitation, the date of uploading the DRP's directions is considered the date of receipt, even if the AO claims to have received it later through email. This interpretation prevents parties from exploiting a later date to their advantage and adheres to a singular, unambiguous approach to reckoning limitation.

Trib.). 14. Bramhacorp Hotels & Resorts Ltd. v. DDIT
103 Taxmann.com 344 · 2019 · ITAT
14
citing judgments

The Assessing Officer must comply with the directions of the Dispute Resolution Panel (DRP) when passing final assessment orders, and failure to do so may warrant setting aside the assessment with a direction for compliance.

Judgments citing directions of the DRP

Hi-Lex India Private Limited, Gurgaon vs. Assessment Unit Income Tax Department, Gurgaon

In the result, Appeal of the Assessee is allowed

ITA 4288/DEL/2024[2020-21]Status: DisposedITAT Delhi28 Nov 2025AY 2020-21

Bench: Shri Yogesh Kumar U.S. & Shri Brajesh Kumar Singh

Section 144(3)Section 144BSection 144C(13)

Adjustment (F=A-E) 1,52,16,721 6. The Assessee filed objections before the DRP and based on the directions of the DRP, Ld. TPO included two of the rejected companies Hi-Lex india Pvt. ltd. Vs. Assessment Unit and excluded two newly introduced comparable companies, use corrected ... been held to be at Arm’s length by the TPO vide order dated 08/07/2024 while passing the order giving effect to the directions of the DRP and the said entry level operating profit margin of 4.19% includes payment of royalty as on operating expense. Therefore, submitted that once

Ethan Energy India Private Limited, Hyderabad, Telangana vs. DCIT., Circle 8(1), Hyderabad

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

ITA 1380/HYD/2024[2021-22]Status: DisposedITAT Hyderabad26 Nov 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Paras S Savla, AdvocateFor Respondent: Smt. U Mini Chandran, CIT-DR
Section 143(3)Section 144CSection 144C(13)Section 144C(15)(b)Section 153Section 153(1)Section 4Section 92C

nature of restricting the time period, within which, the Assessing Officer is required to pass the Final Assessment Order after the Directions of the DRP and not enlarging the limitation provided u/sec.153 of the Act. 10. Similar view has been taken by the Hon’ble Bombay High Court

Epam Systems India Private Limited, Hyderabad vs. DCIT, Circle -8 (1), Hyderabad

In the result, both the appeals of the Assessee are allowed

ITA 83/HYD/2022[2017-18]Status: DisposedITAT Hyderabad26 Nov 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.83 & 498/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Epam Systems India The Dcit & The Acit, Private Limited, Vs. Circle-8(1), Hyderabad – 500 081 Hyderabad. Pan Aaacw2012R (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Shreyas Sardesai राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

For Appellant: CA Shreyas SardesaiFor Respondent: MS U Mini Chandran, CIT-DR
Section 143(3)

u/sec.144C(13) is only a restriction on the Assessing Officer to pass the final order within one month from the receipt of the Directions of the DRP and not enlarging the limitation which is provided u/sec.153 of the Act. The Hon’ble Madras High Court has held that provisions u/sec.144C ... Section 153 B is for a limited purpose to ensure that dehors larger time is available, an order based on the directions of the DRP has to be passed within 30 days from the end of the month of receipt of such directions. The section and the sub-section have

Epam Systems India Private Limited, Hyderabad vs. ACIT, Circle-8(1), Hyderabad

In the result, both the appeals of the Assessee are allowed

ITA 498/HYD/2022[2018-19]Status: DisposedITAT Hyderabad26 Nov 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita Nos.83 & 498/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Epam Systems India The Dcit & The Acit, Private Limited, Vs. Circle-8(1), Hyderabad – 500 081 Hyderabad. Pan Aaacw2012R (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Shreyas Sardesai राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

For Appellant: CA Shreyas SardesaiFor Respondent: MS U Mini Chandran, CIT-DR
Section 143(3)

u/sec.144C(13) is only a restriction on the Assessing Officer to pass the final order within one month from the receipt of the Directions of the DRP and not enlarging the limitation which is provided u/sec.153 of the Act. The Hon’ble Madras High Court has held that provisions u/sec.144C ... Section 153 B is for a limited purpose to ensure that dehors larger time is available, an order based on the directions of the DRP has to be passed within 30 days from the end of the month of receipt of such directions. The section and the sub-section have

Repal Renewables Private Limited, Hyderabad vs. DCIT Circle -3(1), Hyderabad

In the result, both the appeals of the Assessee are allowed

ITA 481/HYD/2022[2018-19]Status: DisposedITAT Hyderabad26 Nov 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.116 & 481/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Repal Renewables Private Limited, The Dcit, Circle-3(1), Vs. Hyderabad. Hyderabad – 500 081 Pan Aagcr9762B (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Sri Harsh R Shah, Advocate & Ca Karan Jain राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

For Appellant: Sri Harsh R Shah, Advocate &For Respondent: MS U Mini Chandran, CIT-DR
Section 115JSection 143(3)Section 153Section 234Section 234BSection 234DSection 270A

u/sec.144C(13) is only a restriction on the Assessing Officer to pass the final order within one month from the receipt of the Directions of the DRP and not enlarging the limitation which is provided u/sec.153 of the Act. The Hon’ble Madras High Court has held that provisions u/sec.144C ... nature of restricting the time period, within which, the Assessing Officer is required to pass the Final Assessment Order after the Directions of the DRP and not enlarging the limitation provided u/sec.153 of the Act. 10. Similar view has been taken by the Hon’ble Bombay High Court

Repal Green Power Private Limited, Hyderabad vs. DCIT Circle -3(1), Hyderabad

In the result, both the appeals of the Assessee are allowed

ITA 474/HYD/2022[2018-19]Status: DisposedITAT Hyderabad26 Nov 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.125/Hyd/2022 Assessment Year 2017-2018 Repal Green Power Private Limited, The Dcit, Circle-8(1), Vs. Hyderabad. Hyderabad – 500 081 Pan Aahcr2187F (Appellant) (Respondent) आ.अपी.सं /Ita No.474/Hyd/2022 Assessment Year 2018-2019 Repal Green Power Private Limited, The Dcit, Circle-3(1), Vs. Hyderabad. Hyderabad – 500 081 Pan Aahcr2187F (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Sri Harsh R Shah, Advocate & Ca Karan Jain राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

For Appellant: Sri Harsh R Shah, Advocate &For Respondent: MS U Mini Chandran, CIT-DR
Section 143(3)Section 234Section 234DSection 270ASection 32Section 32A

u/sec.144C(13) is only a restriction on the Assessing Officer to pass the final order within one month from the receipt of the Directions of the DRP and not enlarging the limitation which is provided u/sec.153 of the Act. The Hon’ble Madras High Court has held that provisions u/sec.144C ... nature of restricting the time period, within which, the Assessing Officer is required to pass the Final Assessment Order after the Directions of the DRP and not enlarging the limitation provided u/sec.153 of the Act. 10. Similar view has been taken by the Hon’ble Bombay High Court

Dodla Dairy Limited, Hyderabad vs. DCIT Circle -8(1), Hyderabad

ITA 466/HYD/2022[2018-19]Status: DisposedITAT Hyderabad26 Nov 2025AY 2018-19

Bench: Us:

For Appellant: Shri Aashik Shah, C.AFor Respondent: Ms. U. Mini Chandran
Section 143(3)Section 144Section 80Section 801BSection 80J

therefore, the A.O. had rightly disallowed the corresponding discounted rate of interest element pertaining to the said loan, which, however, as per the directions of the DRP had already been restricted up to the date of repayment of the said loan. 45 ITA TP 466/Hyd/2022 and 1301/Hyd/2024 Dodla Dairy Limited

Repal Green Power Private Limited, Hyderabad vs. DCIT, Circle 8(1), Hyderabad

ITA 125/HYD/2022[2017-18]Status: DisposedITAT Hyderabad26 Nov 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.125/Hyd/2022

For Appellant: Sri Harsh R Shah, Advocate &For Respondent: MS U Mini Chandran, CIT-DR
Section 143(3)Section 234Section 234DSection 270ASection 32Section 32A

u/sec.144C(13) is only a restriction on the Assessing Officer to pass the final order within one month from the receipt of the Directions of the DRP and not enlarging the limitation which is provided u/sec.153 of the Act. The Hon'ble Madras High Court has held that provisions u/sec.144C

Repal Renewables Private Limited, Hyderabad vs. DCIT, Circle 8(1), Hyderabad

In the result, both the appeals of the Assessee are allowed

ITA 116/HYD/2022[2017-18]Status: DisposedITAT Hyderabad26 Nov 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.116 & 481/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Repal Renewables Private Limited, The Dcit, Circle-3(1), Vs. Hyderabad. Hyderabad – 500 081 Pan Aagcr9762B (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Sri Harsh R Shah, Advocate & Ca Karan Jain राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

For Appellant: Sri Harsh R Shah, Advocate &For Respondent: MS U Mini Chandran, CIT-DR
Section 115JSection 143(3)Section 153Section 234Section 234BSection 234DSection 270A

u/sec.144C(13) is only a restriction on the Assessing Officer to pass the final order within one month from the receipt of the Directions of the DRP and not enlarging the limitation which is provided u/sec.153 of the Act. The Hon’ble Madras High Court has held that provisions u/sec.144C ... nature of restricting the time period, within which, the Assessing Officer is required to pass the Final Assessment Order after the Directions of the DRP and not enlarging the limitation provided u/sec.153 of the Act. 10. Similar view has been taken by the Hon’ble Bombay High Court

Ceb Llc (Earlier Known As Ceb Inc.), United States of America vs. Assistant Commissioner of Income Tax, New Delhi

In the result, the appeal of the assessee is allowed

ITA 2025/DEL/2025[2018-19]Status: DisposedITAT Delhi26 Nov 2025AY 2018-19

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh[Assessment Year: 2018-19] Ceb Llc (Earlier Known As The Assistant Commissioner Ceb Inc.), 1201, Wildson Of Income Tax, Blvd. Arlington, Va 22209, Vs Circle- 1(2)(1), International United States Taxation E-2 Block, Civic Care Of Address Centre, Minto Road, New First International Financial Delhi-110002. Centre, Level-2 Plot No. C-54 & 55, G Block, Bandra Kurla Complex, Bandra East, Mumbai-400051, Maharashtra, India. Pan- Aadct5119K Assessee Revenue

Section 144Section 147Section 148Section 148ASection 153(1)Section 9(1)(vi)

existent company and directed the AO to pass a speaking order regarding the said legal objection raised by the assessee. The said observations / directions of the DRP are as under: “(a) At the outset, the assessee has challenged the validity of the proceedings right from the non issuance of notice

Alstom Transport Sa, Karnataka vs. DCIT, Int. Taxation Circle 1(1)(1), Delhi

In the result, impugned assessment order is set aside and appeal of the assessee is allowed for statistical purpose

ITA 1715/DEL/2025[2022-23]Status: DisposedITAT Delhi26 Nov 2025AY 2022-23

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.1711 To 1715/िद"ी/2025(िन.व. 2011-12, 2013-14 To 2015-16 और 2022-23)

For Appellant: Shri Deepak Chopra & Ms. Priyan TandonFor Respondent: Shri Nikhil Kumar Govila, CIT(DR)

Officer has set the tone of his findings on the issue of assessee having PE India after referring to the assessment orders and directions of the DRP for AY 2010-11 and AY 2018-19 to 2021-22. The Assessing Officer has in extenso reproduced the reply received from ... entire findings of the AO with respect to assessee having a PE in India has roots in the directions of the DRP dated 14.11.2014 for AY 2010-11. No independent findings have been given by the Assessing Officer with regard to assessee having PE in India

Alstom Transport Sa, Karnataka vs. DCIT, Int. Taxation Circle 1(1)(1), Delhi

In the result, impugned assessment order is set aside and appeal of the assessee is allowed for statistical purpose

ITA 1714/DEL/2025[2015-16]Status: DisposedITAT Delhi26 Nov 2025AY 2015-16

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.1711 To 1715/िद"ी/2025(िन.व. 2011-12, 2013-14 To 2015-16 और 2022-23)

For Appellant: Shri Deepak Chopra & Ms. Priyan TandonFor Respondent: Shri Nikhil Kumar Govila, CIT(DR)

Officer has set the tone of his findings on the issue of assessee having PE India after referring to the assessment orders and directions of the DRP for AY 2010-11 and AY 2018-19 to 2021-22. The Assessing Officer has in extenso reproduced the reply received from ... entire findings of the AO with respect to assessee having a PE in India has roots in the directions of the DRP dated 14.11.2014 for AY 2010-11. No independent findings have been given by the Assessing Officer with regard to assessee having PE in India

Alstom Transport Sa, Bangalore vs. DCIT Intl. Taxation Circle 1(1)(1), New Delhi

In the result, impugned assessment order is set aside and appeal of the assessee is allowed for statistical purpose

ITA 1713/DEL/2025[2014-15]Status: DisposedITAT Delhi26 Nov 2025AY 2014-15

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.1711 To 1715/िद"ी/2025(िन.व. 2011-12, 2013-14 To 2015-16 और 2022-23)

For Appellant: Shri Deepak Chopra & Ms. Priyan TandonFor Respondent: Shri Nikhil Kumar Govila, CIT(DR)

Officer has set the tone of his findings on the issue of assessee having PE India after referring to the assessment orders and directions of the DRP for AY 2010-11 and AY 2018-19 to 2021-22. The Assessing Officer has in extenso reproduced the reply received from ... entire findings of the AO with respect to assessee having a PE in India has roots in the directions of the DRP dated 14.11.2014 for AY 2010-11. No independent findings have been given by the Assessing Officer with regard to assessee having PE in India

Alstom Transport Sa, Bangalore vs. DCIT Intl. Taxation Circle 1(1)(1), New Delhi

In the result, impugned assessment order is set aside and appeal of the assessee is allowed for statistical purpose

ITA 1712/DEL/2025[2013-14]Status: DisposedITAT Delhi26 Nov 2025AY 2013-14

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.1711 To 1715/िद"ी/2025(िन.व. 2011-12, 2013-14 To 2015-16 और 2022-23)

For Appellant: Shri Deepak Chopra & Ms. Priyan TandonFor Respondent: Shri Nikhil Kumar Govila, CIT(DR)

Officer has set the tone of his findings on the issue of assessee having PE India after referring to the assessment orders and directions of the DRP for AY 2010-11 and AY 2018-19 to 2021-22. The Assessing Officer has in extenso reproduced the reply received from ... entire findings of the AO with respect to assessee having a PE in India has roots in the directions of the DRP dated 14.11.2014 for AY 2010-11. No independent findings have been given by the Assessing Officer with regard to assessee having PE in India

Alstom Transport Sa, Karnataka vs. DCIT International Taxation, Circle 1(1)(1), New Delhi

In the result, impugned assessment order is set aside and appeal of the assessee is allowed for statistical purpose

ITA 1711/DEL/2025[2011-12]Status: DisposedITAT Delhi26 Nov 2025AY 2011-12

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.1711 To 1715/िद"ी/2025(िन.व. 2011-12, 2013-14 To 2015-16 और 2022-23)

For Appellant: Shri Deepak Chopra & Ms. Priyan TandonFor Respondent: Shri Nikhil Kumar Govila, CIT(DR)

Officer has set the tone of his findings on the issue of assessee having PE India after referring to the assessment orders and directions of the DRP for AY 2010-11 and AY 2018-19 to 2021-22. The Assessing Officer has in extenso reproduced the reply received from ... entire findings of the AO with respect to assessee having a PE in India has roots in the directions of the DRP dated 14.11.2014 for AY 2010-11. No independent findings have been given by the Assessing Officer with regard to assessee having PE in India

Amway India Enterprises Private Limited, New Delhi vs. DCIT, Circle 1(1), Delhi / NFAC, Delhi

Appeal of the assessee is allowed

ITA 5912/DEL/2024[2021-22]Status: DisposedITAT Delhi20 Nov 2025AY 2021-22

Bench: Shri Sudhir Pareek & Shri Manish Agarwalamway India Enterprises Private Dcit, Limited, Circle-1(1), Ground Floor, Elegance Tower, Vs. Delhi/Nfac. Plot No.8, Non Hierarchical Commercial, Jasola, Delhi-110025. Pan-Aaaca5603Q (Appellant) (Respondent)

Section 143(1)(a)Section 143(2)Section 143(3)Section 80GSection 92C

result, the objections raised by the assessee were dismissed by the ld. DRP. 3. The AO after following the directions of the DRP has passed the final assessment order on 28.10.2024 at a total income of Rs. 2,75,65,46,220/- by making addition of Rs.1

Vermeiren India Rehab Private Limited, Tirupati vs. DCIT., Circle-1(1), Tirupati

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

ITA 1315/HYD/2024[2021-22]Status: DisposedITAT Hyderabad19 Nov 2025AY 2021-22

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: Sri Sandeep Bagmar R, AdvocateFor Respondent: MS. U. Mini Chandran, CIT-DR
Section 143(3)Section 144C(5)Section 32

other hand, supporting the Final 25 ITA.No.1315 /Hyd./2024 Assessment Order of the Assessing Officer passed in pursuance to the Directions of the DRP submitted that, the A.O. has rightly disallowed depreciation claimed on the building on the ground that, the building was not completed and ready

Aveva Solutions India LLP, Hyderabad vs. Income Tax Officer, Ward 8(1), Hyderabad

In the result, appeal of the Assessee is allowed

ITA 1170/HYD/2024[2021-22]Status: DisposedITAT Hyderabad19 Nov 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1170/Hyd/2024 Assessment Year – 2021-2022 Aveva Solutions India The Income Tax Officer, Llp, Hyderabad. Vs. Ward-8(1), Pin – 500 008. Hyderabad – 500 084. Pan Aayfa6913G (Appellant) (Respondent) Sri Percy Perdiwala, Advocate िनधा"रती "ारा /Assessee By: Shri Harsh Shah & Ca Karan Jain. राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

For Appellant: Shri Harsh Shah and CA Karan JainFor Respondent: MS U Mini Chandran, CIT-DR
Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 153Section 153(1)Section 153(4)Section 92C

u/sec.144C(13) is only a restriction on the Assessing Officer to pass the final order within one month from the receipt of the Directions of the DRP and not enlarging the limitation 8 ITA.No.1170/Hyd./2024 which is provided u/sec.153 of the Act. The Hon’ble High Court has held ... nature of restricting the time period, within which, the Assessing Officer is required to pass the Final Assessment Order after the Directions of the DRP and not enlarging the limitation provided u/sec.153 of the Act. 23 ITA.No.1170/Hyd./2024 10. Similar view has been taken by the Hon’ble Bombay

Mohhamed Abdul Aziz Khalid, Hyderabad vs. ACIT, (Int Taxn)-1, Hyderabad

In the result, appeal of the Assessee is dismissed

ITA 65/HYD/2023[2015-16]Status: DisposedITAT Hyderabad19 Nov 2025AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.65/Hyd/2023 (िनधा"रण वष"/Assessment Year 2015-2016) Mohammed Abdul Aziz The Asst. Director Of Khalid, Hyderabad. Vs. Income Tax [Intl. Taxn- Pin – 500 036 1], Pan Awwpk9108R Hyderabad. (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca P Murali Mohan Rao राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

For Appellant: CA P Murali Mohan RaoFor Respondent: MS U Mini Chandran, CIT-DR
Section 144CSection 147Section 156

learned DR has submitted that this appeal is not against he Final Assessment Order passed by the Assessing Officer in pursuance to the directions of the DRP, but, since the assessee did not file the objections before the DRP, therefore, the Assessing Officer passed the Final Assessment Order which ... entertain the objections when the Final Assessment Order was already passed by the Assessing Officer. The learned DR has relied upon the directions of the DRP and submitted that the DRP has rightly dismissed the objections of the assessee having no jurisdiction to adjudicate on the final order

Lintas India Private Limited, Mumbai vs. DCIT, Circle 16(1), Mumbai

The appeal of the assessee is partly allowed for statistical purposes

ITA 5889/MUM/2024[2021-22]Status: DisposedITAT Mumbai19 Nov 2025AY 2021-22

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarassessment Year: 2021-22 M/S. Lintas India Private Assessment Unit, Limited, Income Tax Department Or A Wing, 16Th Floor, Deputy Commissioner Of Parinee Crescenzo, Income Tax, Bandra-Kurla Complex, Circle 16(1), Bandra (East), 1) National Faceless Mumbai – 400 051 Assessment Centre (Nafac), Vs. Pan: Aaacl0124F Delhi 2)Aayakar Bhawan, Maharshi Karve Road, New Marine Lines, Churchgate, Mumbai – 400020 (Appellant) (Respondent) Present For: Assessee By : Shri Ajit Jain, Ld. A.R. Shri Karnik Kansara, Ld. A.R Ms. Neha Rai, Ld. A.R. Ms. Sakshi Chimanani, Ld. A.R. Revenue By : Shri Kiran Unavekar, Ld. Sr. D.R. Date Of Hearing : 22.08.2025 Date Of Pronouncement : 19.11.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 15.05.2023, Impugned Herein, Passed By The Ld. Commissioner Of Income Tax (Dispute Resolution Panel-1) (In Short Ld. Commissioner) U/S 144C(5) Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2021-22. 2 M/S. Lintas India Private Limited

For Appellant: Shri Ajit Jain, Ld. A.RFor Respondent: Shri Kiran Unavekar, Ld. Sr. D.R
Section 144Section 144CSection 144C(5)Section 92C

account of GIS services + Rs.1,72,01,346/- on account of GSA services) by observing and holding as under: “6.3 Discussion and Directions of the DRP: 6.3.1 We have considered the contentions of the assessee, the order of the TPO and the facts and circumstances of the case. During ... caused to be made by it. It can be concluded that as per the provisions of Sec. 144C(4) and 144C(5), the directions of the DRP are of the nature of guidance to the AO so as to enable him to complete the assessment. The documents on which reliance