“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

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

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

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

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

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

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

Shell India Markets P. Ltd, Mumbai vs. DCIT Ltu-2, Mumbai

In the result, appeal by assessee is allowed

ITA 2340/MUM/2015[2009-10]Status: DisposedITAT Mumbai14 Nov 2022AY 2009-10

Bench: Shri Vikas Awasthy & Shri S.Rifaur Rahman आअसं.1492/मुं/2015 ("न.व. 2010-11) M/S. Mondelez India Foods Private Limited, Mondelez House, Unit No.2001, 20Th Floor, Tower -3 (Wing C), India Bulls Finance Centre, Parel, Mumbai – 400 013. Pan: Aaacc-0460-H ...... अपीलाथ" /Appellant बनाम Vs. Addl. Commissioner Of Income Tax, Range – 5 (1), Aaykar Bhavan, M.K.Road, Mumbai 400 020. ..... ""तवाद"/Respondent आअसं.1576/मुं/2015 ("न.व. 2009-10) Dy. Commissioner Of Income Tax, (Large Taxpayer Unit)-2,Mumbai, World Trade Centre -1, Cuffe Parade, ...... अपीलाथ" /Appellant Mumbai – 400 005 बनाम Vs. M/S. Shell India Markets Private Ltd. 1018, Maker Chambers –V, 10Th Floor, Nariman Point, Mumbai 400 021 Pan: Aaics-1404-P ..... ""तवाद"/Respondent

For Appellant: Shri J.D. Mistry, Sr. Advocate with Shri Hiten ChandeFor Respondent: Ms. Vatsala Jha ,CIT-DR

Section 143Section 143(3)Section 153Section 92C

dates. 9 ITA NO.1576/MUM/2015(A.Y.2009-10) Date Events 30/01/2014 TPO passed order u/s. 92CA of the Act 28/03/2014 A.O Passed draft assessment order 19/12/2014 Directions of the DRP u/s.144C(15) of the Act 29/01/2015 Final assessment order. The contention of the assessee is that the order passed u/s.92CA

DCIT, (Ltu)-2, Mumbai vs. Shell India Markets Pvt. Ltd., Mumbai

In the result, appeal by assessee is allowed

ITA 1576/MUM/2015[2009-10]Status: DisposedITAT Mumbai14 Nov 2022AY 2009-10

For Appellant: Shri J.D. Mistry, Sr. Advocate with Shri Hiten ChandeFor Respondent: Ms. Vatsala Jha ,CIT-DR

Section 143Section 143(3)Section 153Section 92C

Mondelez India Foods P. Ltd, Mumbai vs. Addl CIT RG 5(1), Mumbai

In the result, appeal by assessee is allowed

ITA 1492/MUM/2015[2010-11]Status: DisposedITAT Mumbai14 Nov 2022AY 2010-11

For Appellant: Shri J.D. Mistry, Sr. Advocate with Shri Hiten ChandeFor Respondent: Ms. Vatsala Jha ,CIT-DR

Section 143Section 143(3)Section 153Section 92C

Praxair India Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

In the result, the appeal filed by the assessee stands allowed as indicated hereinabove

ITA 200/BANG/2021[2016-17]Status: DisposedITAT Bangalore14 Nov 2022AY 2016-17

For Respondent: Shri T. Suryanarayana

Section 92C

contentions of Page 8 of 20 IT(TP)A No. 200/Bang/2021 assessee and upheld the proposed addition by the Ld.AO. Pursuant to the directions of the DRP, the Ld.AO passed the impugned order making additions in the hands of the assessee. Aggrieved by the impugned order passed by the Ld.AO

Joint Commissioner of Income Tax (Ltu), Bangalore vs. M/S Dell International Services India Pvt Ltd, Bangalore

In the result, the appeal of the assessee is partly allowed and the revenue’s appeal is allowed for statistical purposes

ITA 134/BANG/2018[2012-13]Status: DisposedITAT Bangalore11 Nov 2022AY 2012-13

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Shri Praveen Karanth, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 250Section 92CSection 92C(3)

markup on warranty amount as such services are not rendered by the assessee to its AE.” 8.7.1. In the light of the above directions of the DRP, which we are in consonance with the TPO, is directed to reexamine the issue raised in ground 10 afresh. It is ordered accordingly

M/S Dell International Services India Pvt Ltd, Bangalore vs. Joint Commisssioner of Income Tax Ltu, Bangalore

In the result, the appeal of the assessee is partly allowed and the revenue’s appeal is allowed for statistical purposes

ITA 2834/BANG/2017[2012-13]Status: DisposedITAT Bangalore11 Nov 2022AY 2012-13

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Shri Praveen Karanth, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 250Section 92CSection 92C(3)

Dell International Services India Private Limited, Bangalore vs. JCIT, Bangalore

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

ITA 642/BANG/2016[2011-12]Status: DisposedITAT Bangalore11 Nov 2022AY 2011-12

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Shri Praveen Karanth, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 144CSection 92CSection 92C(3)

Aggrieved, the Assessee filed its objections before the DRP. The DRP vide its directions dated 30.12.2015, granted partial relief. Pursuant to the directions of the DRP, the AO passed the final assessment order dated 29.01.2016 in which the aggregate TP adjustment was reworked to Rs. 6,11,35,797/-. Aggrieved ... markup on warranty amount as such services are not rendered by the assessee to its AE.” 8.7.1. In the light of the above directions of the DRP, which we are in consonance with the TPO, is directed to reexamine the issue raised in ground 10 afresh. It is ordered accordingly

JCIT, Bangalore vs. M/S Dell International Services India Pvt. Ltd., Bangalore

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

ITA 641/BANG/2016[2011-12]Status: DisposedITAT Bangalore11 Nov 2022AY 2011-12

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Shri Sri.Pradeep Kumar, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 144CSection 92CSection 92C(3)

Fireeye Cybersecurity Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

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

ITA 292/BANG/2021[2016-17]Status: DisposedITAT Bangalore10 Nov 2022AY 2016-17

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuit(Tp)A No. 292/Bang/2021 Assessment Year : 2016-17 M/S. Mandiant Cyber Security Pvt. Ltd. (Formerly Known As Fireeye The Deputy Cybersecurity Pvt. Commissioner Of Ltd.), Income Tax, No. 5, Front Wing Circle – 3(1)(1), Salarpuria Infinity, Vs. Bengaluru. 2Nd Floor, Bannerghatta Road, Bengaluru – 560 029. Pan: Aaccf1341A Appellant Respondent : Shri T. Suryanarayana, Assessee By Senior Advocate Revenue By : Shri Vilas Shinde, Cit Dr Date Of Hearing : 26-09-2022 Date Of Pronouncement : 10-11-2022 Order Per Beena Pillaipresent Appeal Arises Out Of Order Passed By National E- Assessment Centre, Delhi Dated 30/04/2021 On Following Revised Grounds Of Appeal:

For Respondent: Shri T. Suryanarayana

comparables sought for exclusion / inclusion under the 3 segments which are as under: 2.10 The comparables that remained after giving effect to the directions of the DRP are as under: SWD Sl. Weighted Name of the Company No. Average Kals Information Systems 1. 8.60% Pvt. Ltd. 2. Rheal Software

Intrado Ec India Private Limited, Bengaluru vs. DCIT-Circle-3(1)(1), Bangalore

In the result, the appeal of the assessee is allowed

ITA 239/BANG/2021[2016-17]Status: DisposedITAT Bangalore09 Nov 2022AY 2016-17

Bench: Smt. Beena Pillai & Ms. Padmavathy S

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Shri K. Sankar Ganesh, Jt. CIT(DR)(ITAT)

Section 143(3)Section 153Section 2CSection 40Section 92C

assessee filed its objections before the DRP, who confirmed the additions/disallowances. Aggrieved by the final order of assessment passed pursuant to the directions of the DRP, the assessee is in appeal before the Tribunal. 4. The assessee raised 14 grounds with regard to TP adjustment. During the course of hearing

Aker Powergas P. Ltd, Mumbai vs. DCIT RG 15(1)(1), Mumbai

ITA 2213/MUM/2017[2012-13]Status: DisposedITAT Mumbai31 Oct 2022AY 2012-13

Bench: Shri Kuldip Singh & Shri Gagan Goyalassessment Year: 2012-13

For Appellant: Shri Ketan Ved, A.RFor Respondent: Ms. Samruddhi Dhananjay Hande, D.R

Section 143(3)Section 144BSection 144C(3)Section 92C

expenditure. 3. Effect to directions issued by the Hon'ble DRP 3.1 The learned DCIT erred in not giving effect to the following directions of the DRP passed on 23 December 2016: • Negative turnover and prior period expense of Rs. 15.34.411 Para 4.3.1 at page no. 23 of the DRP

Ravikumar Tirupati Parthasarathy, Bangalore vs. The Deputy Commissioner of Income Tax, Circle-2(1), Bangalore

In the result, the appeal is allowed for statistical purposes

ITA 676/BANG/2022[2019-20]Status: DisposedITAT Bangalore28 Oct 2022AY 2019-20

Bench: Shri N.V. Vasudevan & Ms. Padmavathy Sassessment Year : 2019-20

For Appellant: Shri Arjun Raj, CAFor Respondent: Shri K. Sankar Ganesh, Jt.CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 144C

addition to Rs.64,60,469. The assessee is in appeal before the Tribunal against the final order of assessment in accordance with the directions of the DRP. 3. The only issue contended in this appeal through various grounds raised by the assessee is the cost of acquisition considered

Integra Software Services P. Ltd., Chennai vs. DCIT, Pondicherry

The appeal stands partly allowed in terms of our above order

ITA 736/CHNY/2017[2012-13]Status: DisposedITAT Chennai21 Oct 2022AY 2012-13

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri N. Arjunraj (CA) for Shri. S. Sridhar (Advocate) – Ld. ARFor Respondent: Shri R. Bhoopathi (JCIT) / Shri. Kumar Ajeet Ld. CIT-DR

Section 143(3)Section 144C(5)Section 14ASection 195Section 40Section 43(5)Section 9(1)(vii)Section 92C

above assessment year is contrary to law, facts, and in the circumstances of the case. 2. The DCIT erred in mechanically adopting the directions of the DRP vide order dated 30.12.2016 in computing the taxable total income for the Assessment Year under consideration without assigning proper reasons and justification ... DCIT failed to appreciate that the directions of the DRP for maintaining the additions in the computation of taxable total income were wrong, erroneous, unjustified, incorrect and not sustainable in law. 4. The DCIT erred in adding back Rs.25,11,973/- representing interest at 7.75% on the AE sales receivables

Dover India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-2(1)(1), Bangalore

In the result, appeal of the Assessee is partly allowed

ITA 460/BANG/2022[2017-18]Status: DisposedITAT Bangalore21 Oct 2022AY 2017-18

Bench: Shri N. V. Vasudevan & Shri Chandra Poojariit(Tp)A No.460/Bang/2022 Assessment Year : 2017-18 M/S. Dover India Private Limited, Vs. Dcit, Bagmane Laurel, 1St Floor, Circle – 2(1)(1), Block C, Bagmane Tech Park, Bengaluru. C. V. Raman Nagar, Bengaluru – 560 093. Pan : Aaaci 3920 N Appellant Respondent Assessee By : Shri. Chavali Narayanan, Ca Revenue By : Capt. Pradeep Arya, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 03.10.2022 Date Of Pronouncement : 21.10.2022 O R D E R Per N. V. Vasudevanthis Appeal By The Assessee Is Directed Against The Final Order Of Assessment Dated 29.03.2022 Of National Faceless Assessment Centre, Delhi, (Hereinafter Referred To As The Assessing Officer, “Ao” In Short) Passed U/S.143(3) Read With Section 144C(13) Of The Income Tax Act, 1961 (Act) In Relation To Assessment Year 2017-18. 2. The Assessee In Engaged In The Business Of Providing Software Development Services (Swd Services), To Its Wholly Owned Holding Company. In Terms Of The Provisions Of Sec.92-A Of The Act, The Assessee

For Appellant: Shri. Chavali Narayanan, CAFor Respondent: Capt. Pradeep Arya, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 144C(13)Section 92Section 92ASection 92B(1)Section 92CSection 92C(2)Section 92F

enable him to complete the assessment after considering report of TPO. The AO passes a final assessment order on the basis of directions of the DRP. IT(TP)A No.460/Bang/2022 Page 4 of 18 3. The legislative intent in introducing the new transfer pricing legislation, as available in the Memorandum ... DRP gave certain directions. The AO passed final order of assessment against which the Assessee filed appeal before CIT(A). Based on the directions of the DRP, the AO passed the final order of assessment. To the extent the Assessee did not get relief from the DRP/CIT(A), the Assessee

Essilor India Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-2(1)(1), Bangalore

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

ITA 448/BANG/2022[2017-18]Status: DisposedITAT Bangalore21 Oct 2022AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 448/Bang/2022 Assessment Year : 2017-18 M/S. Essilor India Pvt. Ltd., 10Th Floor, Prestige The Deputy Trade Tower, Commissioner Of 46, Palace Road, Income Tax, High Grounds Circle – 2(1)(1), Sampangi Rama Bangalore. Vs. Nagar, Bengaluru – 560 001. Pan: Aaace4623J Appellant Respondent Assessee By : Shri Chavali Narayan, Ca : Shri Praveen Karanth, Revenue By Cit-Dr Date Of Hearing : 27-07-2022 Date Of Pronouncement : 21-10-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against Order Dated 31/03/2022 Passed By The National Faceless Assessment Centre, Delhi For A.Y. 2017-18 On Following Grounds Of Appeal:

For Appellant: Shri Chavali Narayan, CA

Section 142(1)Section 143(2)Section 14ASection 92Section 92C

Ld.AR submitted that the issues needs to be remanded to the Ld.AO to consider the claims in accordance with the directions of the DRP. We note that the impugned order has not been passed by following the directions of the DRP in respect of the corporate tax issues ... Ld.AO following the draft assessment order. In the interest of justice, we direct the Ld.AO to consider the claims in accordance with the directions of the DRP, having regard to the evidences / details filed by the assessee on these issues. Accordingly, ground nos. 5-7 raised by assessee stands allowed

Synamedia India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle- 6(1)(2), Bangalore

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

ITA 350/BANG/2021[2016-17]Status: DisposedITAT Bangalore21 Oct 2022AY 2016-17

Bench: Shri N.V. Vasudevan & Ms. Padmavathy S

For Appellant: Shri Ankur Pai, AdvocateFor Respondent: Shri

Section 143(2)Section 143(3)Section 92C

DRP, the TP adjustment was enhanced to Rs.40,32,45,354 and the AO passed the final assessment order in accordance with the directions of the DRP. The assessee is in appeal before the Tribunal against the final order of assessment. 3. The assessee raised 19 grounds with respect ... Officer in his order. IT(TP)A No.350/Bang/2021 Page 7 of 25 13. The TPO has passed the order giving effect to the directions of the DRP and has computed the interest on delayed receivables invoice wise with reference to the amount received beyond the credit period / not received within

Mfx Infotech Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle- 4(1)(2), Bangalore

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

ITA 251/BANG/2021[2016-17]Status: DisposedITAT Bangalore21 Oct 2022AY 2016-17

Bench: Shri N.V. Vasudevan & Ms. Padmavathy S.It(Tp)A No. 251/Bang/2021 (Assessment Year: 2016-17)

For Appellant: Shri Padamchand Kincha, CAFor Respondent: Shri Manjunath Karkihalli, CIT-DR

Section 133(6)Section 143(3)Section 144B

Rs.4,94,73,850. The assessee is in appeal before the tribunal against the final order of assessment passed in pursuant to the directions of the DRP. 4. The assessee adopted transfer net margin method (TNMM) as the most appropriate method. The operating profit and operating cost has been taken ... delayed receivables based on the invoice details submitted by the assessee considering the actual period of delay 10. The TPO based on the directions of the DRP recomputed the TP adjustment in software segment as Rs.4,66,55,698 and interest on delayed receivable as Rs.28

M/S. Marvell India Private Limited, Bangalore vs. The Deputy Commissioner of Income Tax, Circle- 4(1)(2), Bangalore

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

ITA 2577/BANG/2019[2015-16]Status: DisposedITAT Bangalore21 Oct 2022AY 2015-16

Bench: Shri N.V. Vasudevan & Ms. Padmavathy S

For Appellant: Shri Mukesh Butani, AdvocateFor Respondent: Shri Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru

Section 143(2)Section 143(3)Section 28

DRP. The assessee is in appeal before the Tribunal against the final assessment order passed by the AO pursuant to the directions of the DRP. 4. During the course of hearing, the ld. AR pressed for only the following grounds:- IT(TP)A No.2577/Bang/2019 Page 3 of 27 “Ground

Michael Page International Recruitment P. Ltd, Mumbai vs. The Dy CIT-14(1)(1), Mumbai

In the result, the appeal is allowed for statistical purposes in the terms indicated above

ITA 1323/MUM/2021[2016-17]Status: DisposedITAT Mumbai17 Oct 2022AY 2016-17

Section 143(3)Section 144C(12)Section 144C(5)

that no useful purpose will be served by remitting the matter to the file of the Assessing Officer as there are no lawful directions of the DRP, which can be implemented by the Assessing Officer- the directions dated 23rd March 2021 are admittedly irrelevant inasmuch as these directions pertain ... Dispute Resolution Panel. 5. Smt Jha, learned Departmental Representative, fairly accepts the factual position with respect to the cut-paste error in the directions of the DRP but points out that when these directions stand rectified under rule 13 of the Income Tax (Dispute Resolution Panel) Rules 2009, the matter

Ocwen Financial Solutions Private Limited, Bangalore vs. Assistant Commissioner of Income Tax, Special Range-5, Bangalore

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

ITA 342/BANG/2021[2016-17]Status: DisposedITAT Bangalore14 Oct 2022AY 2016-17

Bench: Shri George George K, Jm & Shri Laxmi Prasad Sahu, Am It(Tp)A No.342/Bang/2021 : Asst.Year 2016-2017 M/S.Ocwen Financial Solutions The Assistant Commissioner Private Limited Of Income-Tax V. Pritech Park, Survey No.51 To Special Range – 5 64/4, Block No.12, Unit 2, 5B & Bangalore. 6A Floors, Bellandur Village, Sarjapur Marathahalli Ring Road Bengaluru – 560 103. Pan : Aaaco3764E. (Appellant) (Respondent) Appellant By : Sri.Ankur Pai & Sri. K.R.Vasudevan, Advocates Respondent By : Sri.K.Sankar Ganesh, Jcit-Dr Date Of Pronouncement : 14.10.2022 Date Of Hearing : 13.10.2022 O R D E R Per George George K, Jm : This Appeal At The Instance Of The Assessee Is Directed Against Final Assessment Order Dated 30.03.2021 Passed U/S 143(3) R.W.S. 144C(13) Of The I.T.Act. The Relevant Assessment Year Is 2016-2017. 2. The Brief Facts Of The Case Are As Follows: The Assessee Is A Company Engaged In Providing It Enabled Services To Ocwen Mortgage Servicing Inc. Usvi. The Assessee Is A Wholly Owned Subsidiary Of Ocwen Asia Holdings Limited, Mauritius. For The Assessment Year 2016-2017, The Return Of Income Was Filed On 29.11.2016 Declaring Total Income Of Rs.93,31,44,800. The Case Was Selected For Scrutiny

For Appellant: Sri.Ankur Pai & Sri. K.R.Vasudevan, AdvocatesFor Respondent: Sri.K.Sankar Ganesh, JCIT-DR

Section 143(2)Section 143(3)

vide para 3.10 has accepted the assessee's objections and accordingly, directed the TPO to exclude the above three companies. There are other directions of the DRP on TP adjustments on which neither party has raised grounds, except the Revenue on the above exclusion of three companies. 7. Referring ... vide para 3.10 has accepted the assessee's objections and accordingly, directed the TPO to exclude the above three companies. There are other directions of the DRP on TP adjustments on which neither party has raised grounds, except the Revenue on the above exclusion of three companies