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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

Wanbury Limited, Mumbai vs. Income Tax Department, Mumbai

The appeal of the assessee is partly allowed

ITA 6664/MUM/2024[2021-22]Status: DisposedITAT Mumbai20 Mar 2025AY 2021-22

Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am

For Appellant: Shri Madhur Agarwal, AR
Section 143(3)Section 144CSection 153(1)

confirmed the TP adjustment made. The assessee is in appeal against the final order of assessment passed by the AO pursuant to the directions of the DRP. 3. Ground number 1 and 2 pertain to the legal contentions of assessment order being barred by limitation. During the course of hearing ... adjustment could be made. 6. The ld DR on the other hand supported the orders of the TPO and the directions of the DRP. 7. We heard the parties and perused the material on record. The assessee has given guarantees on behalf of its AE to SBI London

Credit Agricole Corporate and Investment Bank, Mumbai vs. The Dy-CIT (Int. Taxation)-2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 749/MUM/2022[2017-18]Status: DisposedITAT Mumbai20 Mar 2025AY 2017-18

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Dcit (International Taxation)- Investment Bank (Formerly 2(1)(1), 1St Floor, Room No. 136, Known As ‘Calyon Bank’) Vs. 11Th Floor, Hoechst House, Scindia House, N.M. Marg, Nariman Point, Mumbai-400021. Ballard Pier, Mumbai-400038. Pan: Aaccc3872B Appellant) : Respondent)

Section 143(3)

hands of the assessee. Aggrieved the assessee raised the objections before the Dispute Resolution Panel (DRP). Pursuant to the directions of the DRP, the total income was computed at Rs.404,21,58,617/- and the income of the Branches assessed in the hands of the assessee at Rs.132 ... applied in assessee's case. 71. The ld DR on the other hand relied on the order of the AO and the directions of the DRP. 72. We heard the parties and perused the material on record. The AO for the year under consideration disallowed the expenditure incurred

Credit Agricole Corporate & Investment Bank, Mumbai vs. The Dy.CIT of Income Tax (Internationsl Taxation) -2(1) (1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1234/MUM/2022[2018-19]Status: DisposedITAT Mumbai20 Mar 2025AY 2018-19

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Dcit (International Taxation)- Investment Bank (Formerly 2(1)(1), 1St Floor, Room No. 136, Known As ‘Calyon Bank’) Vs. 11Th Floor, Hoechst House, Scindia House, N.M. Marg, Nariman Point, Mumbai-400021. Ballard Pier, Mumbai-400038. Pan: Aaccc3872B Appellant) : Respondent)

Section 143(3)

hands of the assessee. Aggrieved the assessee raised the objections before the Dispute Resolution Panel (DRP). Pursuant to the directions of the DRP, the total income was computed at Rs.404,21,58,617/- and the income of the Branches assessed in the hands of the assessee at Rs.132 ... applied in assessee's case. 71. The ld DR on the other hand relied on the order of the AO and the directions of the DRP. 72. We heard the parties and perused the material on record. The AO for the year under consideration disallowed the expenditure incurred

Credit Agricole Corporate & Investment Bank, Mumbai vs. The Jt CIT (International Taxationa), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1027/MUM/2021[2016-17]Status: DisposedITAT Mumbai20 Mar 2025AY 2016-17

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Credit Agricole Corporate & Investment Bank, Vs.11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1165/Mum/2016 (Assessment Year: 2011-12) Dcit (International Taxation)- 1(1)(1), Room No. 114, 1St Floor, Scindia House, N.M. Marg, Ballard Estate, Mumbai-400038. Appellant) Vs. Credit Agricole Corporate & Investment Bank, 11Th & 12Th & 14Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent)

Section 143(3)

hands of the assessee. Aggrieved the assessee raised the objections before the Dispute Resolution Panel (DRP). Pursuant to the directions of the DRP, the total income was computed at Rs.404,21,58,617/- and the income of the Branches assessed in the hands of the assessee at Rs.132 ... applied in assessee's case. 71. The ld DR on the other hand relied on the order of the AO and the directions of the DRP. 72. We heard the parties and perused the material on record. The AO for the year under consideration disallowed the expenditure incurred

Credit Agricole Corporate and Investment Bank, Mumbai vs. ACIT (It) 2 (1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 458/MUM/2019[2014-15]Status: DisposedITAT Mumbai20 Mar 2025AY 2014-15

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Credit Agricole Corporate & Investment Bank, Vs.11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent) 2

Section 143(3)

hands of the assessee. Aggrieved the assessee raised the objections before the Dispute Resolution Panel (DRP). Pursuant to the directions of the DRP, the total income was computed at Rs.404,21,58,617/- and the income of the Branches assessed in the hands of the assessee at Rs.132 ... applied in assessee's case. 71. The ld DR on the other hand relied on the order of the AO and the directions of the DRP. 72. We heard the parties and perused the material on record. The AO for the year under consideration disallowed the expenditure incurred

Credit Agricole Corporate and Investment Bank, Mumbai vs. DCIT (It) 2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 4652/MUM/2017[2013-14]Status: DisposedITAT Mumbai20 Mar 2025AY 2013-14

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As ‘Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent)

Section 143(3)

hands of the assessee. Aggrieved the assessee raised the objections before the Dispute Resolution Panel (DRP). Pursuant to the directions of the DRP, the total income was computed at Rs.404,21,58,617/- and the income of the Branches assessed in the hands of the assessee at Rs.132 ... applied in assessee's case. 71. The ld DR on the other hand relied on the order of the AO and the directions of the DRP. 72. We heard the parties and perused the material on record. The AO for the year under consideration disallowed the expenditure incurred

Credit Agricole Corporate and Investment Bank, Mumbai vs. DCIT (It) 2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 2313/MUM/2017[2012-13]Status: DisposedITAT Mumbai20 Mar 2025AY 2012-13

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As ‘Calyon Bank’) 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Credit Agricole Corporate & Investment Bank, Vs.11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) 2

Section 143(3)

hands of the assessee. Aggrieved the assessee raised the objections before the Dispute Resolution Panel (DRP). Pursuant to the directions of the DRP, the total income was computed at Rs.404,21,58,617/- and the income of the Branches assessed in the hands of the assessee at Rs.132 ... applied in assessee's case. 71. The ld DR on the other hand relied on the order of the AO and the directions of the DRP. 72. We heard the parties and perused the material on record. The AO for the year under consideration disallowed the expenditure incurred

Credit Agricole Corporate and Investment Bank, Mumbai vs. DCIT (It) 2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1273/MUM/2016[2011-12]Status: DisposedITAT Mumbai20 Mar 2025AY 2011-12

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Credit Agricole Corporate & Investment Bank, Vs. 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Appellant) Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent) 2

Section 143(3)

hands of the assessee. Aggrieved the assessee raised the objections before the Dispute Resolution Panel (DRP). Pursuant to the directions of the DRP, the total income was computed at Rs.404,21,58,617/- and the income of the Branches assessed in the hands of the assessee at Rs.132

DCIT (It) 2(1)(1), Mumbai vs. Credit Agricole Corporate and Investment Bank, Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1165/MUM/2016[2011-12]Status: DisposedITAT Mumbai20 Mar 2025AY 2011-12

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Credit Agricole Corporate & Investment Bank, Vs.11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1165/Mum/2016 (Assessment Year: 2011-12) Dcit (International Taxation)- 1(1)(1), Room No. 114, 1St Floor, Scindia House, N.M. Marg, Ballard Estate, Mumbai-400038. Appellant) Vs. Credit Agricole Corporate & Investment Bank, 11Th & 12Th & 14Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent)

Section 143(3)

hands of the assessee. Aggrieved the assessee raised the objections before the Dispute Resolution Panel (DRP). Pursuant to the directions of the DRP, the total income was computed at Rs.404,21,58,617/- and the income of the Branches assessed in the hands of the assessee at Rs.132 ... applied in assessee's case. 71. The ld DR on the other hand relied on the order of the AO and the directions of the DRP. 72. We heard the parties and perused the material on record. The AO for the year under consideration disallowed the expenditure incurred

ADIT (It) 1(2), Mumbai vs. Credit Agricole Corporate and Investment Bank, Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1839/MUM/2015[2010-11]Status: DisposedITAT Mumbai20 Mar 2025AY 2010-11

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Dcit (International Taxation)- Investment Bank (Formerly 2(1)(1), 1St Floor, Room No. 136, Known As ‘Calyon Bank’) Vs. 11Th Floor, Hoechst House, Scindia House, N.M. Marg, Nariman Point, Mumbai-400021. Ballard Pier, Mumbai-400038. Pan: Aaccc3872B Appellant) : Respondent)

Section 143(3)

hands of the assessee. Aggrieved the assessee raised the objections before the Dispute Resolution Panel (DRP). Pursuant to the directions of the DRP, the total income was computed at Rs.404,21,58,617/- and the income of the Branches assessed in the hands of the assessee at Rs.132 ... applied in assessee's case. 71. The ld DR on the other hand relied on the order of the AO and the directions of the DRP. 72. We heard the parties and perused the material on record. The AO for the year under consideration disallowed the expenditure incurred

Credit Agricole Corporate and Investment Bank, Mumbai vs. DCIT (It) 2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1479/MUM/2015[2010-11]Status: DisposedITAT Mumbai20 Mar 2025AY 2010-11

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As ‘Calyon Bank’) 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent)

Section 143(3)

hands of the assessee. Aggrieved the assessee raised the objections before the Dispute Resolution Panel (DRP). Pursuant to the directions of the DRP, the total income was computed at Rs.404,21,58,617/- and the income of the Branches assessed in the hands of the assessee at Rs.132 ... applied in assessee's case. 71. The ld DR on the other hand relied on the order of the AO and the directions of the DRP. 72. We heard the parties and perused the material on record. The AO for the year under consideration disallowed the expenditure incurred

Reckitt Benckiser India Private Limited, Gurgaon, Haryana vs. D.C.I.T., Circle 11.1, Kolkata

ITA 2319/KOL/2024[2021-2022]Status: DisposedITAT Kolkata18 Mar 2025AY 2021-2022

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma

For Respondent: Shri Deepak Chopra, AR & Shri Rohan Khare, AR
Section 143(3)Section 144C(13)Section 144C(5)Section 92BSection 92C

above grounds of appeal, on the facts and in the circumstances of the case, the AQ/TPO have erred in not following the directions of the DRP which is binding as per the provisions of section 144C(10) of the Act by not reducing expenses in connection with sales promotion ... prejudice to above grounds of appeal, on the facts and in the circumstances of the case, the Assessing Officer/TPO erred in not following directions of the DRP pursuant to which no adjustment on account of AMP is required in the case of the appellant. 3(m) Without prejudice to above

Reckitt Benckiser (India) Pvt. Ltd., Gurgaon vs. D.C.I.T., Circle - 11(1), Kolkata

In the result, the appeals of the assessee are partly allowed for statistical purposes

ITA 1801/KOL/2024[2020-2021]Status: DisposedITAT Kolkata18 Mar 2025AY 2020-2021

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarmaita Nos.78/Kol/2018 Assessment Year: 2013-14 &

For Appellant: Shri Deepak Chopra, AR & Shri Rohan Khare, ARFor Respondent: Shri Guru Bhashyam, CIT, DR
Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 92BSection 92C

above grounds of appeal, on the facts and in the circumstances of the case, the AQ/ TPO have erred in not following the directions of the DRP which is binding as per the provisions of section 144C(10) of the Act by not reducing expenses in connection with sales promotion ... prejudice to above grounds of appeal, on the facts and in the circumstances of the case, the Assessing Officer/TPO erred in not following directions of the DRP pursuant to which no adjustment on account of AMP is required in the case of the appellant. 3(m) Without prejudice to above

Reckitt Benckiser (India) Pvt Ltd., Kolkata vs. DCIT, Circle-12(1), Kolkata

In the result, the appeals of the assessee are partly allowed for statistical purposes

ITA 2631/KOL/2019[2015-16]Status: DisposedITAT Kolkata18 Mar 2025AY 2015-16

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarmaita Nos.78/Kol/2018 Assessment Year: 2013-14 &

For Appellant: Shri Deepak Chopra, AR & Shri Rohan Khare, ARFor Respondent: Shri Guru Bhashyam, CIT, DR
Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 92BSection 92C

above grounds of appeal, on the facts and in the circumstances of the case, the AQ/ TPO have erred in not following the directions of the DRP which is binding as per the provisions of section 144C(10) of the Act by not reducing expenses in connection with sales promotion ... prejudice to above grounds of appeal, on the facts and in the circumstances of the case, the Assessing Officer/TPO erred in not following directions of the DRP pursuant to which no adjustment on account of AMP is required in the case of the appellant. 3(m) Without prejudice to above

Reckitt Benckiser (India) Pvt Ltd., Kolkata vs. DCIT, Circle-12(1), Kolkata

In the result, the appeals of the assessee are partly allowed for statistical purposes

ITA 78/KOL/2018[2013-14]Status: DisposedITAT Kolkata18 Mar 2025AY 2013-14

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarmaita Nos.78/Kol/2018 Assessment Year: 2013-14 &

For Appellant: Shri Deepak Chopra, AR & Shri Rohan Khare, ARFor Respondent: Shri Guru Bhashyam, CIT, DR
Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 92BSection 92C

above grounds of appeal, on the facts and in the circumstances of the case, the AQ/ TPO have erred in not following the directions of the DRP which is binding as per the provisions of section 144C(10) of the Act by not reducing expenses in connection with sales promotion ... prejudice to above grounds of appeal, on the facts and in the circumstances of the case, the Assessing Officer/TPO erred in not following directions of the DRP pursuant to which no adjustment on account of AMP is required in the case of the appellant. 3(m) Without prejudice to above

Reckitt Benckiser (India) Private Limited, Kolkata vs. DCIT, Circle-12(1), Kolkata

ITA 2681/KOL/2018[2014-15]Status: DisposedITAT Kolkata18 Mar 2025AY 2014-15
Section 143(3)Section 144C(10)Section 144C(13)Section 92BSection 92C

above grounds of appeal, on the facts and in the circumstances of the case, the AQ/TPO have erred in not following the directions of the DRP which is binding as per the provisions of section 144C(10) of the Act by not reducing expenses in connection with sales promotion ... prejudice to above grounds of appeal, on the facts and in the circumstances of the case, the Assessing Officer/TPO erred in not following directions of the DRP pursuant to which no adjustment on account of AMP is required in the case of the appellant. 3(m) Without prejudice to above

Roechling Industrial India Private Limited, Gujarat vs. The Deputy Commissioner of Lncome Tax, Circle 3(1)(1), Mumbai

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

ITA 6722/MUM/2024[AY 2021-22]Status: DisposedITAT Mumbai17 Mar 2025

Bench: Smt. Beena Pillai () & Shri Renu Jauhri ()

Section 143(3)Section 144BSection 153Section 234A

DRP'), on the following grounds: On the facts, and circumstances of the case, and in law, the learned AO has, based on the directions of the DRP, erred in making additions of INR 1,61,14,337 to the Appellant's total income. 2. On the facts and circumstances

Raziulla Syed, Hyderabad vs. ITO (Int Taxn)-2, Hyderabad

In the result, appeal of the Assessee is allowed

ITA 986/HYD/2024[2017-18]Status: DisposedITAT Hyderabad11 Mar 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA P Murali Mohan RaoFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 132Section 142(1)Section 144C(5)Section 147Section 148Section 148ASection 195

Officer in absence of any documentary evidences/bank statements vide directions dated 29.02.2024 passed u/sec.144C(5) of the Act. 3.6. Pursuant to the above directions of the DRP dated 29.02.2024, the Assessing Officer passed his final assessment order dated 02.03.2024 u/sec.147 r.w.s.144C(13) of the Act by making additions on account

Nagajyothi Myneni, Hyderabad vs. ADIT., (Int Taxn)-1, Hyderabad

In the result, appeal of the Assessee is allowed

ITA 109/HYD/2023[2020-21]Status: DisposedITAT Hyderabad11 Mar 2025AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA P Murali Mohan RaoFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 142(1)Section 143(2)Section 143(3)Section 144C(5)

Rs.38,03,780/-; respectively. Accordingly, the DRP passed it’s directions dated 15.12.2022 u/sec.144C(5) of the Act. 2.2. Pursuant to the above directions of the DRP, the Assessing Officer passed final assessment order dated 13.01.2023 u/sec.143(3) r.w.s.144C(13) of the Act, by determining the long term capital gains ... Rs.38,03,780/- paid to S. Naga Basi Reddy towards furniture works which is through banking channel and also not implemented the directions of the DRP wherein the DRP had allowed the expenses incurred towards payment to made to Matrix Technologies for solar water hearing; of Rs.1

Harsco India Private Limited, Hyderabad vs. DCIT., Circle 2(1), Hyderabad

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

ITA 1041/HYD/2024[2021-22]Status: DisposedITAT Hyderabad06 Mar 2025AY 2021-22

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita No.1041/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2021-22) Harsco India (P) Ltd Vs. Dy. Commissioner Of Hyderabad Income Tax, Circle 2(1) Pan:Aacch0555L Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Ca Suvibha Nolka राज" व "ारा/Revenue By:: Shri B Bala Krishna, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 08/01/2025 घोषणा की तारीख/Pronouncement: 06/03/2025 आदेश/Order

For Appellant: CA Suvibha NolkaFor Respondent: : Shri B Bala Krishna, CIT(DR)
Section 143(3)Section 144C(5)

directed against the assessment order dated, 06/09/2024, passed u/s 143(3) r.w.s. 144C(13) of the I.T. Act, 1961, in pursuant to the directions of the DRP, dated 19/08/2024 passed u/s 144C(5) of the Act for the A.Y.2021-22. 2. The assessee has raised the following grounds of appeal: Page