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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

Faisal Badruddin Shitware, Mumbai vs. Income Tax Officer (Int Tax Ward)-4(2)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 4081/MUM/2025[2016-17]Status: DisposedITAT Mumbai23 Sept 2025AY 2016-17

Bench: Smt. Beena Pillai & Smt. Renu Jauhrifaisal Badruddin Ao Ward 4(2)(1), Kautilya Shitware Bhavan, Bandra Kurla 307, 1A, Delux Nagar Vs. Complex, Mumbai 400051 Building, Jeevan Baug, Post Room No. 209, 2Nd Floor, Office Road, Mumbra, Thane Aayakar Bhavan, M.K. Road, 400612 Mumbai 400020 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Bvops1660L (Appellant) (Respondent) निर्ााररती की ओर से / Assessee By: Shri. Nishit Gandhi /Revenue By: Shri Krishna Kumar Sr. Dr Date Of Hearing 06.08.2025 Date Of Pronouncement 23.09.2025 आदेश/O R D E R Per Renu Jauhri [A.M]: This Appeal Is Filed By The Assessee Against The Order Of The Ao Ward 4(2)(1), Mumbai Dated 17.12.2024 Passed As Per The Directions Of The Dispute Resolution Panel (Drp) U/S. 144C(5) Of The Income Tax Act, 1961 [Hereinafter Referred To As "Act"] For Assessment Year [A.Y.] 2016-17. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri. Nishit GandhiFor Respondent: Shri Krishna Kumar SR. DR
Section 115BSection 144CSection 144C(5)Section 147Section 151ASection 153Section 5Section 69

adjudicated in appropriate circumstances as per the submission of Ld. AR. Ground No. 3: 7. On merits, the assessee has challenged the directions of the DRP for sustaining the addition of Rs. 7 lacs u/s. 69 of the Act. Out of these, Rs. 5 lacs have been deposited in cash

Tata Nyk Shipping Pte Ltd, Singapore vs. Deputy Commissioner of Income-Tax (International Tax), Circle 3(1)(1), Delhi

In the result, impugned order is set aside and appeal of the assesee is allowed

ITA 247/DEL/2025[2018-19]Status: DisposedITAT Delhi23 Sept 2025AY 2018-19

Bench: Shri Vikas Awasthy & Shri Naveen Chandraआअसं.247/िद"ी/2025(िन.व. 2018-19) Tata Nyk Shipping Pte Ltd. 6 Shenton Way, #18-08B, Oue Downtown, 2, Singapore-068809 ...... अपीलाथ"/Appellant Pan: Aadct-9945-P बनाम Vs. Deputy Commissioner Of Income Tax, (International Taxation), ..... "ितवादी/Respondent Circle 3(1)(1), Civic Centre, Minto Road, Delhi 110002

For Appellant: S/Shri Ajay Vohra, Sr. Advocate with Aditya Vohra, AdvocateFor Respondent: Shri Nikhil Kumar Govila, CIT-DR
Section 147Section 263Section 44B

held the receipts as royalty taxable in India at the rate of 10% on gross basis. The AO failed to comply with the directions of the DRP. 5. Shri Nikhil Kumar Govila, representing the department fairly stated that the issue raised by the assessee in present appeal has been considered ... examine whether the department is in appeal against the order of Hon’ble High Court. We are of considered view that such directions by the DRP are superfluous as the appeal of the Revenue before the Hon’ble High Court was dismissed on the statement made by Senior Standing Counsel

Birla Carbon India Private Limited, Mumbai vs. The Principal Commissioner of Income Tax, Mumbai - 5, Mumbai

In the result, the appeal is allowed as indicated above

ITA 3768/MUM/2025[2018-19]Status: DisposedITAT Mumbai22 Sept 2025AY 2018-19

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiyabirla Carbon India Private Limited The Principal Commissioner Of Ground Floor, Aditya Birla Centre, Income Tax Room No. 515, 5Th Floor, Aaykar S. K. Ahire Marg, Worli, Vs. Mumbai-400 030 Bhavan, M. K. Road, Mumbai-400 020 Pan/Gir No. Aascs 9916 L (Appellant) : (Respondent) Appellant By : Shri Madhur Agarwal Respondent By : Shri Satyaprakash R. Singh Date Of Hearing : 16.09.2025 Date Of Pronouncement : 22.09.2025 O R D E R Per Saktijit Dey: In The Present Appeal, The Assessee Has Called Into Question The Validity Of The Order Dated 25.03.2025, Passed U/S. 263 Of The Income Tax Act, 1961 (‘The Act’ For Short) By Learned Principal Commissioner Of Income Tax (‘Ld.Pcit’ For Short), Pertaining To The Assessment Year (A.Y.) 2018-19. 2. Thought Multiple Grounds Have Been Raised In The Memorandum Of Appeal, However, The Assessee Has Raised A Pertinent Preliminary Issue, Challenging The Competence & Jurisdiction Of Ld. Pcit To Invoke Powers U/S. 263 Of The Act To Revise An Assessment Order Passed U/S. 144C(13) Of The Act, In Pursuance To The Directions Of Learned Dispute Resolution Panel (Ld. Drp).

For Appellant: Shri Madhur AgarwalFor Respondent: Shri Satyaprakash R. Singh
Section 143(3)Section 144C(1)Section 144C(13)Section 263Section 92C

whether ld. PCIT can validly assume jurisdiction u/s. 263 of the Act to revise an assessment order passed in pursuance to the directions of the DRP. Pertinently, section 144C of the Act providing the alternate dispute resolution mechanism by way of reference to ld. DRP was incorporated ... order, in terms with sub-section 13 of section 144C, the A.O. has to pass the final assessment order in conformity with the directions of ld. DRP without providing any further opportunity of being heard to the assessee. Thus, a reading of sub-section 13 of section 144C makes

Akansha Garg, Delhi vs. ACIT, Circle Int. Tax-1(3)(1), Delhi

In the result, the Appeal of the Assessee is partly allowed for

ITA 1383/DEL/2025[2022-23]Status: DisposedITAT Delhi19 Sept 2025AY 2022-23

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Akansha Garg, Vs. Acit, 313/36, C-1, Inderlok, Circle Int. Tax-1(3)(1), New Delhi-110035 New Delhi-110002

Section 143(3)Section 144C

Commissioner of Income Tax, Circle, Intl. Tax-1(3)(1), dated 06/01/2025 for the Assessment Year 2022-23. 2. In consequent to the directions of the DRP, the A.O. passed the Final Assessment Order on 06.01.2025 u/s 143(3) r.w.s. 144C(13) of the 2 AkanshaGarg Act. Aggrieved

Factive Limited, Mumbai vs. Assistant Commissioner of Income Tax, (International Taxation )-2(3)(1), Mumbai

In the result, both the appeals are partly allowed

ITA 4706/MUM/2023[2021-22]Status: DisposedITAT Mumbai15 Sept 2025AY 2021-22

Bench: Shri Saktijit Dey & Shri Girish Agrawal & Factive Limited Asst. Cit(It)-2(3)(1) C/O. Price Waterhouse & Co. Llp 609, 6Th Floor, Kautilya Bhavan, 252, Veer Savarkar Marg, C-41, C-43, G Block, Vs. Shivaji Park, Dadar, Bandra Kurla Complex, Mumbai-400 028 Bandra (E), Mumbai Pan/Gir No. Aaccf 5745 J (Appellant) : (Respondent) : Shri Dhanesh Bafna A/W Appellant By Shri Yogesh Malpani & Ms. Kinjal Patel Respondent By : Shri Krishna Kumar (Sr. Dr) Date Of Hearing : 21.08.2025 Date Of Pronouncement : 15.09.2025 O R D E R Per Saktijit Dey: Captioned Appeals By The Assessee Are Against The Final Assessment Orders Passed U/S. 143(3) R.W.S 144C(13) Of The Income Tax Act, 1961 (‘The Act’ For Short), In Pursuance To The Directions Of Learned Dispute Resolution Panel (‘Ld. Drp' For Short) & Pertains To The Assessment Years (A.Y.) 2021-22 & 2022-23. 2. Since The Substantive Issue On Merits, Arising In The Appeals Are More Or Less Common In Both The Appeals, We Propose To Take Up Ita No. 4706/Mum/2023, Pertaining To A.Y. 2021-22, As The Lead Appeal. (A.Ys. 2021-22 & 2022-23) Factive Limited Vs. Asst. Cit(It) 3. Ground Nos. 1, 2 & 3 Are Basically On Legal Issues, Challenging The Validity Of The Final Assessment Order. At The Outset, Ld. Counsel Appearing For The Assessee Submitted That He Would Prefer To Address The Issues On Merits And, If Warranted, May Press The Legal Grounds.

For Respondent: Shri Krishna Kumar (Sr. DR)
Section 143(3)Section 9(1)(vi)

assessee’s objections on both counts, i.e., nature of the receipt as ‘royalty’ as well as existence of DAPE. In terms with the directions of ld. DRP, the A.O. finalized the assessment. That is how the assessee is before us. 14. At the time of hearing, ld. Counsel appearing ... year under consideration, only the assessee has a right to appeal against the Final Assessment Order framed by the AO after incorporating the directions of the DRP and the Department does not have any such right of appeal, unless there is an appeal by the Applicant Assessee. It is pertinent

Sanjay Mehta, Jaipur vs. DCIT Circle (Intl Tax), Jaipur

ITA 201/JPR/2025[2018-19]Status: DisposedITAT Jaipur12 Sept 2025AY 2018-19
For Appellant: Shri Rohan Sogani, C.AFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 132Section 144C(5)Section 153CSection 69B

consequence at this juncture, still thePanel considers it imperative to make a mention in this regard. 8. In compliance with the directions of the DRP, the AO passed the final assessment orders under Section 153C read with Section 144C(13) on 23.01.2025and 27.01.2025 for the assessee and Urvashi Mehta ... consequence at this juncture, still thePanel considers it imperative to make a mention in this regard. 8. In compliance with the directions of the DRP, the AO passed the final assessment orders under Section 153C read with Section 144C(13) on 23.01.2025and 27.01.2025 for the assessee and Urvashi Mehta

Gemological Institute of America, Inc., United States vs. The Assistant Commissioner of Income-Ta (International Taxation) - Circle 2(3)(2), Mumbai

In the result, appeals of the assesse are allowed partly for statistical

ITA 1293/MUM/2025[2022-23]Status: DisposedITAT Mumbai09 Sept 2025AY 2022-23

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Anikesh Banerjee, Hon'Ble

For Appellant: Shri J.D. Mistry, Sr. Adv. & Shri Niraj Sheth, A/RsFor Respondent: Shri Satya Pal Kumar, CIT D/R a/w Shri Krishna Kumar, Sr. D/R
Section 144C(13)Section 147Section 148

earlier AYs and taxed in similar lines as in earlier assessment years. Basis the findings in earlier assessment orders and following the directions of the DRP, the AO computed the total income for AY 2019-20 as under:- AY 2019-20 Particulars Business Income attributable to PE as discussed ... 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 en able him to complete the assessment. The documents on which

Gemological Institute of America, Inc., United States vs. The Assistant Commissioner of Income-Tax (International Taxation), Circle 2(3)(2) - Mumbai, Mumbai

In the result, appeals of the assesse are allowed partly for statistical

ITA 1292/MUM/2025[2019-20]Status: DisposedITAT Mumbai09 Sept 2025AY 2019-20

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Anikesh Banerjee, Hon'Ble

For Appellant: Shri J.D. Mistry, Sr. Adv. & Shri Niraj Sheth, A/RsFor Respondent: Shri Satya Pal Kumar, CIT D/R a/w Shri Krishna Kumar, Sr. D/R
Section 147Section 148

earlier AYs and taxed in similar lines as in earlier assessment years. Basis the findings in earlier assessment orders and following the directions of the DRP, the AO computed the total income for AY 2019-20 as under:- AY 2019-20 Particulars of Income Amount in INR Business Income attributable ... 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 en able him to complete the assessment. The documents on which

Virendra M Gaidhane, Mumbai vs. ITO, Ward 2(3)(1), Mumbai

In the result, assessee’s appeal in ground no-1 is allowed

ITA 64/MUM/2025[2022-23]Status: DisposedITAT Mumbai05 Sept 2025AY 2022-23

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

For Appellant: Shri Nishit Gandhi a/w Ms. Aadnya BhandariFor Respondent: Shri Krishna Kumar (SR DR)
Section 143(3)Section 144C(13)Section 144C(5)

passed in compliance to the statutory provisions that mandate in terms of Section 144C(13) of the Act that upon receipt of the directions of the DRP, the Ld. AO shall in conformity with the directions complete the assessment without providing any further opportunity of being heard to the assessee ... terms of section 144C(13) of the Act, the Assessing Officer was obliged to pass final order of assessment in accordance with the directions of the DRP. In the present case, final order of assessment does not incorporate the directions of the DRP and is verbatim repetition of the draft

M/S. Hydro Bs India Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-3(1)(1), Bengaluru

The appeal of the assessee is partly allowed

ITA 2117/BANG/2024[2020-21]Status: DisposedITAT Bangalore04 Sept 2025AY 2020-21

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year: 2020-21

For Appellant: Shri Harsha, CAFor Respondent: Dr. Divya K J, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 144CSection 92CSection 92C(3)(c)

order of the DCIT-3(1)(1) is not justified in law and on the facts and circumstances of the case. 2. The Directions of the DRP are not justified in law and on facts and circumstances of the case. 3. As regards the DRP directions dated

Munich Re Automation Solutions Limited, Ireland vs. Assistant Commissioner of Income Tax, Circle International Tax, 2(2)(1), New Delhi

In the result, appeal of the assessee is partly allowed

ITA 3766/DEL/2023[2021-22]Status: DisposedITAT Delhi04 Sept 2025AY 2021-22

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.3766/िद"ी/2023(िन.व. 2021-22) Munich Re Automation Solutions Ltd., 2Nd Floor, Mountain View, Central Park, Leopardstown Office Park, Dublin, Ireland ...... अपीलाथ"/Appellant Pan : Aaicm-2594-E बनाम Vs. Assistant Commissioner Of Income Tax, ..... "ितवादी/Respondent Circle International Tax-2(2)(1), New Delhi अपीलाथ" "ारा/ Appellant By : Shri Vishal Kalra, Ms. Reema Grewal & Ms. Snigdha Gautam, Advocates "ितवादी"ारा/Respondent By : Ms. Ekta Jain, Cit-Dr & Ms. Neeju Gupta, Sr. Dr सुनवाई क" ितिथ/ Date Of Hearing : 06/06/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 04/09/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Assessment Order Dated 25.10.2023 Passed U/S. 143(3) R.W.S. 144C(13) Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’), For Ay 2021-22. 2. Shri Vishal Kalra, Advocate Appearing On Behalf Of The Assessee At The Outset Submitted That He Is Not Pressing Ground No. 2 Of Appeal Challenging Validity Of Assessment Order On The Ground Of Limitation.

For Appellant: Shri Vishal Kalra, Ms. Reema Grewal, and Ms. Snigdha Gautam, AdvocatesFor Respondent: Ms. Ekta Jain, CIT-DR &
Section 143(3)Section 9(1)(vi)

submissions on ground no. 3 and 4, the assessee has assailed final assessment order as the AO has erred in not following the directions of the DRP to allow credit of equalization levy paid at 2% against the Income Tax payable on the amount assessed as royalty. The assessee ... said amount as refund. 9. On the other hand, Ms. Ekta Jain representing the department vehemently defended the impugned assessment order and directions of the DRP and prayed 5 for dismissing appeal of the assessee. The ld. DR referring to para 7 of the final assessment order submits that

Microsoft Corporation (India) Pvt Ltd, Delhi vs. DCIT (16) (1) Delhi, Delhi

Appeal of the assessee is allowed

ITA 1862/DEL/2022[2017-18]Status: DisposedITAT Delhi04 Sept 2025AY 2017-18

Bench: Shri Mahavir Singh, Vice Presdient (), Shri Vikas Awasthy & Shri Brajesh Kumar Singhआअसं.1862/िद"ी/2022 (िन.व. 2017-18) Microsoft Corporation (India) P. Ltd., 807, New Delhi House, Barakhamba Road, New Delhi 110001 ...... अपीलाथ"/Appellant Pan: Aaacm-5586-C बनाम Vs. Deputy Commissioner Of Income-Tax, Circle 16(1), Central Revenue Building, ..... "ितवादी/Respondent Ip Estate, Delhi अपीलाथ" "ारा/ Appellant By : S/Shri Nageswar Rao, (Through Vc) & Parth, Advocates "ितवादी"ारा/Respondent By : Shri Rajesh Kumar, Cit- Dr सुनवाई क" ितिथ/ Date Of Hearing : 04/09/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 04/09/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Assessment Order Dated 30.06.2022, Passed U/S. 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961, (Hereinafter Referred To As ‘The Act’) For Assessment Year 2017-18. 2. Shri Nageswar Rao, Appearing On Behalf Of The Assessee Submitted At The Outset That, At This Stage He Is Confining His Submissions To Ground No. 1 Of Appeal

For Appellant: S/Shri Nageswar Rao, (Through VC) &For Respondent: Shri Rajesh Kumar, CIT- DR
Section 143(3)Section 144C(13)Section 144C(5)

required to pass final assessment order within one month from the end of month in which directions of the DRP are received. He pointed that directions of the DRP were uploaded on ITBA portal on 01.04.2022.To support his contention, he referred to letter dated 29.07.2022 at page ... paper book received from the office of DRP. He further pointed that as per the aforesaid letter the directions of the DRP were also communicated to the AO through speed post dispatched on 04.04.2022. Since, the DRP directions were conveyed to the AO in the month of April, the Assessing

Richemont India Private Limited, New Delhi vs. Deputy Commissioner of Income Tax, Circle 19(1), New Delhi

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

ITA 3688/DEL/2024[2020-21]Status: DisposedITAT Delhi29 Aug 2025AY 2020-21

Bench: Shri Sudhir Pareek & Shri Manish Agarwalrichemont India Private Dy. Cit, Limited, Circle-19(1), Unit No.6B, 6Th Floor, Aria Vs. New Delhi. Tower, Hotel J.W. Mariott, Aerocity Asset Area-4, Hospitality District, Delhi-110037. Pan-Aadcr9256R (Appellant) (Respondent) Assessee By Ms. Reema Malik, Adv. Department By Shri Dharm Veer Singh, Cit-Dr Date Of Hearing 28/08/2025 Date Of Pronouncement 28/08/2025 O R D E R [ Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Assessment Order Dated 18.06.2024 Passed By The Income Tax Officer In Compliance To The Direction Given By The Drp.

Section 144C(5)

thus, submitted by the Ld. AR there remained no adjustment after passing the order of TPO giving effect to the directions of the DRP, therefore, necessary directions be given to the AO for taking the said order on record as the AO has passed the final assessment order without considering

Accenture Solutions Private Limited, Mumbai vs. Dy. Commissioner of Income Tax, Mumbai

In the result, the appeal is allowed as indicated above

ITA 3457/MUM/2025[2017-18]Status: DisposedITAT Mumbai28 Aug 2025AY 2017-18

Bench: Shri Saktijit Dey, Vp & Shri Girish Agrawal, Am Accenture Solutions Private Limited Pr. Cit, 501, 5Th Floor, Plat 3, Godrej & Boycee Compound, Vikhroli (W), Vikhroli S.O., Vs. Aayakar Bhavan, M. K. Road, Mumbai-400 079 Mumbai-400 020 Pan/Gir No. (Appellant) : (Respondent) Appellant By : Shri Nishant Thakkar Respondent By : Shri Satya Pal Kumar Date Of Hearing : 18.08.2025 Date Of Pronouncement : 28.08.2025 O R D E R Per Saktijit Dey, Vp: The Captioned Appeal Has Been Filed By The Assessee, Assailing The Order Dated 20.03.2025, Passed U/S. 263 Of Income Tax Act, 1961 (‘The Act’ For Short) By Learned Principal Commissioner Of Income Tax, Mumbai-6 (‘Ld. Pcit’ For Short), Pertaining To The Assessment Year (A.Y.) 2017-18. 2. We Have Heard The Parties & Perused The Materials Available On Record. The Short Issue Arising For Consideration Is Whether The Final Assessment Order Passed U/S. 144C(13) Of The Act, Can Be Subjected To Revisionary Jurisdiction U/S. 263 Of The Act. For Deciding This Issue, Few Necessary Facts Are Required To Be Considered. The Assessee Is A Resident Corporate Entity Engaged In The Business Of Providing Information Technology (It)/Information Technology Enabled Service (Ites) To Its Group Companies As Well As Consulting Services To Its Clients. For The Assessment Year Under Dispute, The Assessee Filed

For Appellant: Shri Nishant ThakkarFor Respondent: Shri Satya Pal Kumar
Section 143(3)Section 144C(13)Section 263Section 80G

short). 4. After considering the submissions of the assessee, ld. DRP disposed of the objections vide directions dated 07.06.2022. In terms with the directions of ld. DRP, the A.O. finalized the assessment vide order dated 25.07.2022, passed u/s. 143(3) r.w.s. 144C(13) r.w.s. 144B of the Act. When ... whether ld. PCIT can validly assume jurisdiction u/s. 263 of the Act to revise an assessment order passed in pursuance to the directions of the DRP. Pertinently, section 144C of the Act providing the alternate dispute resolution mechanism by way of reference to ld. DRP was incorporated

Panda Srinivas, Hyderabad vs. ADIT (Int Taxn)-2, Hyderabad

ITA 682/HYD/2025[2018-19]Status: DisposedITAT Hyderabad26 Aug 2025AY 2018-19

Bench: Us:

Section 143(2)Section 144C(1)Section 144C(5)Section 147Section 148Section 148ASection 54F

that as the order passed by the A.O. u/s 147 r.w.s. 144C(13) of the Act, dated 21.12.2024 was in pursuance to the directions of the DRP–1, Bengaluru, therefore, 9 Panda Srinivas an appeal against the said order was maintainable before the Income Tax Appellate Tribunal and not before ... that the appeal against the final assessment order passed u/s 147 r.w.s. 144C(13) of the Act, dated 21.12.2024 based on the directions of the DRP-1, Bengaluru was not maintainable before him. 11. Per contra, Shri Gurupreet Singh the learned Senior Departmental Representative (for short, “Ld. DR”) rebutted

Kaliyaperumal Padmanaban, Cuddalore vs. ITO, Ward-2, Cuddalore

In the result, appeal filed by the assessee is allowed

ITA 1176/CHNY/2025[2012-13]Status: DisposedITAT Chennai25 Aug 2025AY 2012-13

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.N. Arjun Raj, AdvocateFor Respondent: Ms. Anitha, Addl. CIT
Section 144

fact that the impugned final assessment order had electronically generated valid DIN which order alone is challengable before the ITAT and that the directions of the DRP merged with the final assessment orders serves only as a guidance to the Assessing Officers to pass the final assessment orders." 5. Mr.Karthik ... another communication and therefore, the requirement under the circular has been complied with; and that in any case, assessee had not challenged the directions issued by DRP and therefore, the impugned assessment order ought not to have been quashed. 6. Mr. Balaji, learned counsel for respondent/assessee submitted that apart from

Adp Private Limited, Hyderabad vs. DCIT., Circle 1(1), Hyderabad

In the result, appeal of the Assessee is partly allowed

ITA 975/HYD/2024[2020-21]Status: DisposedITAT Hyderabad22 Aug 2025AY 2020-21

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: CA, Sriram SeshadriFor Respondent: MS. U Mini Chandran, CIT-DR
Section 143(3)Section 144C(1)Section 144C(5)Section 153Section 195Section 234ASection 40Section 92C

favour of the appellant-company, thereby, resulting in deletion of TP margin adjustment. The Assessing Officer passed Final Assessment Order incorporating the Directions of the DRP vide order passed u/sec.143(3) r.w.s.144C(13) r.w.s.144B of the Income Tax Act, 1961, Dated 31.07.2024 wherein the Assessing Officer has made additions towards

Narayanan, Chromepet vs. Income Tax Officer, Chennai

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

ITA 695/CHNY/2025[2018-2019]Status: DisposedITAT Chennai20 Aug 2025AY 2018-2019

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.695/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 Narayanan, Vs. The Income Tax Officer, F-1, 37/60, Guru Balaji Apts, International Taxation Ward 2(1), First Main Road, New Colony, Chennai. Chromepet, Chennai 600 044. [Pan:Ackpn6481A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : None ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 24.07.2025 घोषणा की तारीख /Date Of Pronouncement : 20.08.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Final Assessment Order Dated 06.01.2025 Passed By The Income Tax Officer, International Taxation Ward 2(1), Chennai Under Section 147 R.W.S. 144C(13) Of The Income Tax Act, 1961 [“Act” In Short] For The Assessment Year 2018-19. 2. When The Appeal Was Taken Up For Hearing On 24.07.2025, We Find No Representation On Behalf Of The Assessee. However, We Find Paper

For Appellant: NoneFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 142(1)Section 143(2)Section 144C(1)Section 147Section 148Section 69

failed to furnish any kind of documentary evidence to substantiate his claim of payment of brokerage for ₹.1,30,000/-. As per the directions of the DRP, the Assessing Officer computed the long term capital gains at ₹.5,69,344/- and brought to tax and completed the assessment under section ... that the assessee failed to substantiate his claim of cost of acquisition with documentary evidence and also payment of brokerage. Accordingly, as per directions of the DRP, the Assessing Officer determined long term capital gain to an extent of ₹.5,69,344/- as against the addition on account of short

Indian Metals and Ferro Alloys Ltd, Bhubaneswar vs. DCIT, Circle-1(1), Bhubaneswar

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

ITA 506/CTK/2024[2021-22]Status: DisposedITAT Cuttack19 Aug 2025AY 2021-22

Bench: Shri Duvvuru Rl Reddy(Kz) & Shri Rakesh Mishra

Section 143(1)Section 143(2)Section 143(3)Section 144C(5)Section 234BSection 234CSection 270ASection 92CSection 92D

dated 28.10.2024, which has I.T.A. No.: 506/CTK/2024 Assessment Year: 2021-22 Indian Metals and Ferro Alloys Ltd. been passed after considering the directions of the DRP u/s 144C(5) of the Act, dated 30.09.2024. 2. The assessee is in appeal before the Tribunal raising the following grounds of appeal

Jaldhi Overseas Pte. Ltd., Singapore vs. ACIT/DCIT, International Taxation-1(2), Chennai

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

ITA 366/CHNY/2025[2022-23]Status: DisposedITAT Chennai19 Aug 2025AY 2022-23

Bench: Shri Manu Kumar Giri & Shri Amitabh Shuklaआयकर अपील सं./Ita No.366/Chny/2025 िनधा"रण वष"/Assessment Year: 2022-23 V. Jaldhi Overseas Pte. Ltd., The Assistant Commissioner Of #25-60, Tong Eng Building, 101, Cecil Income Tax, International Street, Singapore 069533. Taxation, Dcit, Intl. Tax 1(2), C/O. Bothra Shipping Services Private Chennai. Limited, Vasundhara, 9Th Floor, Unit-A, 2/7 Sarat Bose Road, L.R. Sarani S.O., Kalkata, West Bengal 700 020. [Pan: Aadcj0165F] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Shri Ashik Shah, C.A. ""थ" की ओर से /Respondent By : Ms. E. Pavuna Sundari, Cit सुनवाईकीतारीख/Date Of Hearing : 13.08.2025 घोषणाकीतारीख /Date Of Pronouncement : 19.08.2025 आदेश / O R D E R Per Manu Kumar Giri, Jm:

For Appellant: Shri Ashik Shah, C.AFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 143(2)Section 143(3)Section 144C(1)Section 144C(13)Section 153Section 44B

addition proposed by the Assessing Officer in the draft assessment order and rejected the grounds raised by the assessee. As per the directions of the DRP under section 144C(5) of the Act dated 29.11.2024, the Assessing Officer concluded that the shipping income earned by the assessee is not eligible