COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION AND TRANSFER PRICING vs. SIGNIFY HOLDING B V

Accordingly, the appeal fails and is dismissed

Bench: : The Hon’Ble The Chief Justice T.S. Sivagnanam & The Hon’Ble Justice Chaitali Chatterjee (Das) Date: 6Th May, 2025 Appearance: Mr. Vipul Kundalia, Sr. Adv. Mr. Soumen Bhattacharjee, Adv. Mr. Ankan Das, Adv. Mr. Anindya Kanan, Adv. Ms. Shradhya Ghosh, Adv. …For Appellant

condone the delay in filing the appeal. The application IA No: GA/1/2025 is allowed. The assessee preferred the appeal before the learned Tribunal against the directions issued by the Dispute Resolution Panel (DRP) under Section 144C(5) of the Act dated December 22, 2022 for the assessment year 2020-21 passed against a draft assessment order under Section 144C