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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

Open Text Technologies India Private Limited, Hyderabad vs. Dy. Commissioner of Income Tax, Circle-16(2), Hyderabad

ITA 2387/HYD/2018[2014-15]Status: DisposedITAT Hyderabad05 May 2025AY 2014-15

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Madhusudan Sawdia, Hon'Ble

For Appellant: Revenue byFor Respondent: Date of hearing
Section 143(3)Section 92B

Aggrieved with the draft assessment order passed by the Ld. AO, the assessee preferred objections before the Ld. DRP. In pursuance to the directions of Ld. DRP dated 27.08.2018, the Ld. AO finalized the assessment on 29.10.2018 by making total addition of Rs.16,21,20,521/- on account of upward ... segmental data only in respect of the Software Development Services and not in respect of product sales. He has referred to the directions of the DRP and submitted that the business of this company is primarily Software Development and Services and system integration and support. The Software Development and Services

Wns Global Services Private Limited, Mumbai vs. Asessment Unit, National Faceless Assessment Centre, New Delhi

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

ITA 4432/MUM/2024[AY 2020-2021]Status: DisposedITAT Mumbai05 May 2025

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankarwns Global Services Private Vs Assessment Unit, National Faceless Limited, Mumbai Assessment Centre, New Delhi Pl-10/11, Gate No.4, Godrej- Boyce Complex, Pirojshanagar, L.B.S.Marg, Vikhroli (West), Mumbai-400 079 Pan: Aaacw2598L Appellant Respondent

For Appellant: ShriPorus Kaka A/w Manish KanthFor Respondent: Shri Pankaj Kumar (CIT DR)
Section 143(3)Section 144BSection 144CSection 144C(13)Section 144C(5)Section 253

section 144C(5) dated 03/05/2024, adjudicated the objections raised by the assessee and considered the findings of the TPO. Subsequently, based on the directions of the DRP, the Ld. AO passed the final assessment order under section 144C(13) of the Act. 6 ITA 4432/Mum/2024 WNS Global Service Private Limited ... record. The Ld.AR primarily argued the TP issue related to the jurisdiction of the Ld.AO in making addition by disobeying the direction of the DRP which contravening the provisions of section 144C(13) of the Act. In TP adjustment, the addition was made on two issues which are covered

International Seaport Dredging Limited, Chennai vs. DCIT, Chennai

The appeal stand allowed

ITA 72/CHNY/2018[2013-14]Status: DisposedITAT Chennai02 May 2025AY 2013-14

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकर अपील सं./ Ita No.72/Chny/2018 (िनधा)रणवष) / Assessment Year: 2013-14) & आयकर अपील सं./ It (Tp)A No.35/Chny/2018 (िनधा)रणवष) / Assessment Year: 2014-15) & आयकर अपील सं./ It (Tp)A No.87/Chny/2019 (िनधा)रणवष) / Assessment Year: 2015-16) M/S. International Seaport Dredging Dcit / Jcit(Osd) Private Limited, Corporate Circle-2(2) बनाम 5Th Floor, Challam Towers, Chennai. Old No.62, New No.113, / Vs. Dr.Radhakrishnan Salai Chennai-600 004. "थायीलेखासं./जीआइआरसं./Pan/Tan No. Aabci-2286-E (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Ashik Shah (C.A) – Ld.Ar ""थ"कीओरसे/Respondent By : Shri A.Sasi Kumar (Cit) -Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 05-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 02-05-2025 आदेश / O R D E R Per Manu Kumar Giri, Jm: These Appeals By Assessee For Assessment Years (Ay) 2013-14 & 2014-15 Arise Out Of The Separate Orders Of Assessments Framed By Ld.

For Appellant: Shri Ashik Shah (C.A) – Ld.ARFor Respondent: Shri A.Sasi Kumar (CIT) -Ld. DR
Section 143(3)

quantitative filters. 10. The lower authorities have, in facts and circumstances of the case and in law, erred in not following the direction of Ld. DRP to exclude three comparable companies with regard to transaction of deputation of personnel. 11. The lower authorities have, in facts and circumstances ... made an adjustment to the revenue amounting to INR 0.30 crores and INR 0.22 crores, respectively. Subsequent to the Directions of the DRP, the TPO revised the arm's length margin of comparable companies to 40.25% for AY 2014-15 and accordingly, revised the upward adjustment to INR 0.28 crores

Vinod Kumar Jangir, Jhunjhunu vs. Dct, Circle (Intl Tax), Jaipur

Appeal is allowed and the impugned assessment

ITA 779/JPR/2024[2013-14]Status: DisposedITAT Jaipur01 May 2025AY 2013-14

Bench: Shri Gagan Goyal & Shri Narinder Kumarmr. Vinod Kumar Jangir, C/O. Yashi Super Market, Vishwakarma Complex, Gandhi Chowk, Distt. Jhunjhunu -333001 Pan No. Arzpj 7960G ...... Appellant Vs.

For Appellant: Mr. R. S. Poonia, C.A., Ld. ARFor Respondent: Mrs. Alka Gautam, CIT, Ld. DR
Section 139(4)Section 144CSection 147Section 148Section 148ASection 69

preferred the present appeal before us. 3. We have gone through the draft assessment order passed u/s. 144C (3), directions of the DRP u/s. 144C (5) of the Act and final assessment order passed u/s. 147 r.w.s. 144C (13) of the Act alongwith the submissions of the assessee and grounds

International Air Transport Association, Mumbai (for Sending Notices) vs. Deputy Commissioner of Income Tax (International Taxation) - Circle 2(2)(1), Mumbai

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

ITA 3330/MUM/2023[2020-21]Status: DisposedITAT Mumbai29 Apr 2025AY 2020-21

Bench: Smt. Beena Pillai & Smt. Renu Jauhriआयकर अपील सं./Ita No. 3330/Mum/2023 (निर्धारण वर्ा / Assessment Year :2020-21) International Air V/S. Dcit (It), Circle 2(2)(1), Transport Association बिधम Mumbai C/O Ernst & Young Llp Room No. 1722, 17Th Floor, 14Th Floor, The Ruby, 29, Air India Building, Senapati Bapat Marg, Nariman Point, Mumbai, Dadar (West), Mumbai, Maharashtra-400021 Maharashtra-400028 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aacci4695N Appellant/अपीलधर्थी .. Respondent/प्रनिवधदी

For Appellant: Shri Porus Kaka and Shri DiveshFor Respondent: Shri Krishna Kumar

raised by the revenue, wherein it had challenged the scaling down of the quantum of revenue attributed by the A.O pursuant to the directions of the DRP is dismissed as having been rendered as infructuous.” 4.4. Thus, the above decision of the coordinate bench has thoroughly examined all aspects ... change in the facts and circumstances in this year, we hold that the addition made by the Ld. AO, on the direction of Ld. DRP, on account of the provision of distance learning courses is not justified and is, therefore, deleted. P a g e | 18 A.Y. 2020-21 International

Royal Canin India Private Limited, Mumbai vs. Assistant Commissioner of Income-Tax, Mumbai

Appeal is hereby dismissed

ITA 6816/MUM/2024[2021-22]Status: DisposedITAT Mumbai28 Apr 2025AY 2021-22

Bench: Shrivikram Singh Yadav & Shri Anikesh Banerjeeroyal Canin India Pvt Ltd Vs Assistant Commissioner Of Income- 1401 & 1402, F Wing, 14Th Tax, Circle 3(1)(1), Floor, Lotus Corporate Park, Aayakar Bhavan, M.K. Road, Cts No.185/A, Graham Firth Mumbai-400 020 Compound, Western Express Highway, Goregaon (East), Mumbai-400 063 Pan: Aadcr4417J Appellant Respondent

For Appellant: ShriK.M. Gupta a/w Shri AnmolFor Respondent: Shri Pankaj Kumar (CIT DR)
Section 143(3)Section 144BSection 144CSection 144C(13)

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

Somnath Konduru, United States vs. I.T.O (Int Taxn)-1, Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 179/HYD/2024[2015-16]Status: DisposedITAT Hyderabad21 Apr 2025AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA K C DevdasFor Respondent: Shri B Bala Krishna, CIT-DR
Section 144Section 144CSection 144C(1)Section 144C(13)Section 144C(2)Section 144C(5)Section 148

date” prescribed under the Act i.e., 05.04.2023 and not maintainable in terms of section 144C(2) of the Act. In pursuant to directions of the DRP, the Assessing Officer passed final assessment order under section 144 read with section 144C(13) of the Act on 26.12.2023 and assessed total income

Shakti Hormann Private Limited, Hyderabad vs. DCIT Circle -3(1), Hyderabad

In the result, appeals filed by the assessee for both the assessment years 2017-18 and 2018-19 are partly allowed

ITA 452/HYD/2022[2018-19]Status: DisposedITAT Hyderabad21 Apr 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita-Tp No.451/Hyd/2022 & 452/Hyd/2022 (निर्धारण वर्ा/Assessment Year: 2017-18 & 2018-19) Shakti Hormann Private Vs. Asst.Commissioner Of Limited Income Tax Hyderabad Circle-3(1) [Pan : Aadcs4024Q] Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri P.Murali Mohan Rao, Ar रधजस् व द्वधरध/Revenue By: Shri B.Bala Krishna, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 15/04/2025 घोर्णध की तधरीख/ 21/04/2025 Date Of Pronouncement: आदेश / Order Per Vijay Pal Rao: These Appeals Filed By The Assessee Are Directed Against The Assessment Orders Dated 21.07.2022 & 28.07.2022 Passed U/S 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961 (“The Act”) In Pursuant To The Directions Of The Dispute Resolution Panel (“The Drp”) U/S 144C(5) Of The Act For The Assessment Year 2017-18 & 2018-19 Respectively. 2. For The Assessment Year 2017-18, The Assessee Has Raised The Following Grounds Of Appeal :

For Appellant: Shri P.Murali Mohan Rao, ARFor Respondent: Shri B.Bala Krishna, CIT-DR
Section 143(3)Section 144C(5)Section 92C

rate for international loan is LIBOR based. Hence, the DRP rightly directed the assessing officer to adopt the LIBOR rates. We confirm the directions of the DRP.” 9.2 Aurobindo Pharma Ltd. Vs. ACIT, [2014] 42 Taxmann.com 556 (Hyd. In this case, the coordinate bench has held as under ... contribution, though this issue is decided by the DRP in favour of the assessee, however, the AO has not given effect to the directions of the DRP. Now this issue is covered by the judgement of Hon’ble Supreme Court in the case of Checkmate Services

United Overseas Bank Limited, Mumbai vs. Assistant Commissioner of Income-Tax, Mumbai

The appeal of the assessee is partly allowed

ITA 3486/MUM/2023[2020-21]Status: DisposedITAT Mumbai21 Apr 2025AY 2020-21

Bench: Shri Pawan Singh, Jm & Ms Padmavathy S, Am

For Appellant: Shri Madhur Agarwal, ARFor Respondent: 09.04.2025
Section 143(2)Section 143(3)Section 144Section 144C(13)Section 147Section 153Section 270ASection 37Section 44C

assessee. The assessee is in appeal before the Tribunal against the final order passed by the AO in accordance with the directions of the DRP. 4. The ld. AR submitted that the HO expenses allocated to the assessee are towards the Directors Fees and remuneration which is allocated ... Kuwait [2011] 9 taxmann.com 309 (Mum.). 6. The ld. DR on the other hand relied on the order of the AO and the directions of the DRP. 7. We heard the parties and perused the material on record. The assessee during the year under consideration has claimed deduction under section

Shell International Petroleum Company Limited, Mumbai vs. Deputy Commissioner of Income Tax (Int Taxation)_4(2)(1), Mumbai

Accordingly we hold that the treatment of IT services is not in the nature of FTS and cannot be taxed in India. Ground No.25 to 27 are allowed and Ground No

ITA 3317/MUM/2023[2020-21]Status: DisposedITAT Mumbai21 Apr 2025AY 2020-21

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

For Respondent: Shri Vivek Perampurna, CIT-DR
Section 143(3)

royalty. The assessee is in appeal before the Tribunal against the final order of assessment passed by the AO as per the directions of the DRP. Treatment of BSS as FTS 4. We heard the parties and perused the material on record. With regard to treatment ... number of users. The ld. AR drew our attention to the findings given by the DRP in para- 12.3.1 of the directions wherein the DRP has held that GSAP maintenance charges are similar to SUN Maintenance Charges to submit that the nature of software being accepted as identical the decision

Shell International Petroleum Company Limitedium, Mumbai vs. Dy Commissioner of Income Tax (International Taxation)-4(2)(1), Mumbai

Accordingly we hold that the treatment of IT services is not in the nature of FTS and cannot be taxed in India. Ground No.25 to 27 are allowed and Ground No

ITA 995/MUM/2022[2018-19]Status: DisposedITAT Mumbai21 Apr 2025AY 2018-19

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

For Respondent: Shri Vivek Perampurna, CIT-DR
Section 143(3)

royalty. The assessee is in appeal before the Tribunal against the final order of assessment passed by the AO as per the directions of the DRP. Treatment of BSS as FTS 4. We heard the parties and perused the material on record. With regard to treatment ... number of users. The ld. AR drew our attention to the findings given by the DRP in para- 12.3.1 of the directions wherein the DRP has held that GSAP maintenance charges are similar to SUN Maintenance Charges to submit that the nature of software being accepted as identical the decision

Shell International Petroleum Company Ltd., Mumbai vs. DCIT (It) 4(2)(1), Mumbai

Accordingly we hold that the treatment of IT services is not in the nature of FTS and cannot be taxed in India. Ground No.25 to 27 are allowed and Ground No

ITA 2307/MUM/2022[2019-20]Status: DisposedITAT Mumbai21 Apr 2025AY 2019-20

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

For Respondent: Shri Vivek Perampurna, CIT-DR
Section 143(3)

royalty. The assessee is in appeal before the Tribunal against the final order of assessment passed by the AO as per the directions of the DRP. Treatment of BSS as FTS 4. We heard the parties and perused the material on record. With regard to treatment ... number of users. The ld. AR drew our attention to the findings given by the DRP in para- 12.3.1 of the directions wherein the DRP has held that GSAP maintenance charges are similar to SUN Maintenance Charges to submit that the nature of software being accepted as identical the decision

M/S. Shell Interational Petroleum Co. Ltd., Mumbai vs. Dy CIT (International Taxation)-4(2)(1), Mumbai

ITA 1244/MUM/2021[2017-18]Status: DisposedITAT Mumbai21 Apr 2025AY 2017-18

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

Section 143(3)Section 234ASection 271(1)(c)

royalty. The assessee is in appeal before the Tribunal against the final order of assessment passed by the AO as per the directions of the DRP. Treatment of BSS as FTS 4. We heard the parties and perused the material on record. With regard to treatment ... number of users. The ld. AR drew our attention to the findings given by the DRP in para- 12.3.1 of the directions wherein the DRP has held that GSAP maintenance charges are similar to SUN Maintenance Charges to submit that the nature of software being accepted as identical the decision

M/S Shell International Petroleum Company Ltd., Mumbai vs. Dy CIT (It)- 4 (2)(1), Mumbai

ITA 7499/MUM/2019[2016-17]Status: DisposedITAT Mumbai21 Apr 2025AY 2016-17

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

For Appellant: Respondent)For Respondent: Shri Vivek Perampurna, CIT-DR
Section 143(3)Section 271(1)(c)

royalty. The assessee is in appeal before the Tribunal against the final order of assessment passed by the AO as per the directions of the DRP. Treatment of BSS as FTS 4. We heard the parties and perused the material on record. With regard to treatment ... number of users. The ld. AR drew our attention to the findings given by the DRP in para- 12.3.1 of the directions wherein the DRP has held that GSAP maintenance charges are similar to SUN Maintenance Charges to submit that the nature of software being accepted as identical the decision

Aptivaa Middle East Fze, Dubai vs. Deputy Commissioner of Income Tax, Circle 1(1)(2), International Taxation, Mumbai

The appeal of the assessee is allowed

ITA 1985/MUM/2024[2014-15]Status: DisposedITAT Mumbai15 Apr 2025AY 2014-15

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri Khirendra M. Gupta, ARFor Respondent: Shri Krishna Kumar- Sr. DR
Section 143(2)Section 143(3)Section 147Section 148Section 149(1)Section 149(1)(b)Section 271(1)(e)Section 274Section 6(3)(ii)

merits. The assessee is in appeal before the Tribunal against the final order of assessment passed by the AO pursuant to the directions of the DRP. 3. Though the assessee has raised several contentions on the validity of the reassessment proceedings, during the course of hearing the ld AR mainly

Hempel Singapore Pte Ltd, Mumbai vs. Deputy Commissioner of Income Tax International Taxation Circle 2(2)(2), Mumbai

Appeal are allowed

ITA 946/MUM/2025[2022-23]Status: DisposedITAT Mumbai11 Apr 2025AY 2022-23

Bench: Shri Pawan Singh, Jm & Ms Padmavathy S, Am

For Respondent: Shri Krishna Kumar- Sr. DR
Section 143(3)Section 144BSection 144C(13)Section 147Section 153Section 9

assessee is in appeal before the Tribunal against the final order of assessment passed by AO as per the directions of the DRP. Hempel Singapore Pte. Ltd. 3. We heard the parties and perused the material on record. The ld. AR during the course of hearing submitted that

Transunion International Inc., Mumbai vs. Deputy Comm. of Income Tax (International Taxation)-4(1)(2), Mumbai

Appeal of the assessee is allowed

ITA 2698/MUM/2022[2017-18]Status: DisposedITAT Mumbai11 Apr 2025AY 2017-18

Bench: Shri Pawan Singh, Jm & Ms Padmavathy S, Am

For Appellant: Shri J.D. Mistry, Sr. Adv. a/w
Section 142(1)Section 143(3)Section 144CSection 47

addition. The assessee is in appeal before the Tribunal against the final order of assessment passed by the AO as per the directions of the DRP. 4. With regard to the admission of the additional grounds No.13 & 14 raised vide letter dated 29.07.2024, we heard the parties and perused ... page no. 222 of Paper Book) filed by the assessee raising the following two questions: (i) The date on which the directions of the DRP were uploaded on ITBA Portal. (ii) Date on which it was communicated to Jurisdictional AO by email/ITBA Portal/any other means. 6. The ld. AR further

Aon Consulting Private Limited, New Delhi vs. DCIT, Circle-1(1), Delhi

In the result, appeal of the assessee is partly allowed in the terms aforesaid

ITA 739/DEL/2022[2017-18]Status: DisposedITAT Delhi09 Apr 2025AY 2017-18

Bench: Shri Vikas Awasthy & Shri Pradip Kumar Kediaआअसं.739/िद"ी/2022(िन.व. 2017-18) M/S Aon Consulting P. Ltd., Aon Centre, 9Th To 11Th, Building No.2, Unitech Realty Projects Ltd., (Sez), Village Tikri, Sector 48, Gurgaon, Haryana 122001 ...... अपीलाथ"/Appellant Pan: Aahca-0739-J बनाम Vs. Deputy Commissioner Of Income Tax, ..... "ितवादी/Respondent Circle 1(1), Delhi Assessee By : Shri Darpan Kirpalani, Advocate Department By : S/Shri Rajesh Kumar & Rajesh Kumar Dhanesta, Sr. Dr सुनवाई क" ितिथ/ Date Of Hearing : 17/01/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 09/04/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed The Assessment Order Dated 22.02.2022 Passed U/S. 143 R.W.S. 144C(13) R.W.S 144B Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’). 2. The Assessee In Appeal Has Assailed Transfer Pricing Adjustment Made In Respect Of Software Development Services Segment. The Assessee Has Also Assailed Some Additions On Corporate Issue, Viz. Disallowance Made U/S. 14A R.W.S. 8D & Additions Based On Intimation U/S. 143(1) Of The Act.

For Appellant: Shri Darpan Kirpalani, AdvocateFor Respondent: S/Shri Rajesh Kumar & Rajesh Kumar Dhanesta, Sr. DR
Section 143Section 143(1)Section 14A

principle the DRP accepted that activities of Sasken are not functionally different from that of the assessee. The TPO while giving effect to directions of the DRP without even looking at the financials of Sasken Technologies Ltd. and in violation of directions of the DRP excluded the company from ... respect of ITeS segment is available and directed AO/TPO to verify and pass order accordingly. The TPO, while giving effect to the directions of the DRP, has not given any observations with regard to availability of segmental data. The ld. Counsel referred to financials of Tata Elxsi Ltd. at page

Jc Bamford Excavators Ltd., England vs. ACIT (International Taxation), Circle-2(1)(2), New Delhi

In the result, appeal of the Assessee is partly allowed

ITA 625/DEL/2021[2017-18]Status: DisposedITAT Delhi09 Apr 2025AY 2017-18

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandraआ.अ.सं/.I.T.A No.625/Del/2021 िनधा"रणवष"/Assessment Year:2017-18 बनाम Jc Bamford Excavators Ltd., Acit Rocester, Uttoxeter, St 14, Vs. (International Taxation), 5Jp, Staffordshire, England. Circle-2(1)(2), Room No.508, 5Th Floor, D-Block, Civic Centre, Pan No.Aabcj6004D Newdelhi. अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 144C(5)

Assessee against the final assessment order dated 26/03/2021 passed u/s 143(3) r.w.s. 144C(13) for the AY 2017-18 pursuant to the directions of the DRP dated 15/12/2020 u/s 144C(5) of the Income Tax Act, 1961. Assessee in its appeal raised the following grounds of appeal: - 1. “That

Meethale Purayil Hashim, Payangadi vs. Income Tax Officer, Ward Int. Tax, Kozhikode

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

ITA 210/COCH/2025[2015-16]Status: DisposedITAT Cochin08 Apr 2025AY 2015-16

Bench: Shri Inturi Rama Rao

For Appellant: Sri.Muhammed Ashraf, AdvocateFor Respondent: Sri.Sanjith Kumar Das, CIT-DR
Section 139(1)Section 144C(1)Section 144C(13)Section 147Section 148Section 148ASection 149(1)

holding that the appellant had failed to respond to the notices issued u/s.148A(b) dated 26th March, 2022. Pursuant to the directions of the DRP, final assessment order was passed on 27.01.2025 by the AO passed u/s.144C(13) r.w.s. 147 of the Act. 3. Being aggrieved, the appellant