This compilation indexes twelve rulings — eleven from the Income Tax Appellate Tribunal (across Delhi, Bangalore, Hyderabad, and Chennai benches) and one from the Telangana High Court — that were pronounced between 7 July 2026 and 28 July 2026 and in which Section 144C(13) of the Income Tax Act, 1961 featured as a cited provision. The cases span a range of taxpayer profiles including foreign companies, non-resident individuals, and domestic entities operating in international taxation circles. The compilation is intended for in-house tax teams, Big-4 associates, and law firm researchers who need a structured, citable index of recent adjudication under this provision.

Research index only. This page is a structured case-law reference tool. Nothing on this page constitutes legal, tax, or professional advice. Readers must verify all citations against the full text of each judgment and should consult qualified advisers before acting on any legal position.

The statutory framework in one paragraph

Section 144C of the Income Tax Act, 1961 establishes the Dispute Resolution Panel (DRP) mechanism, which applies to eligible assessees — primarily foreign companies and transfer pricing cases. Under Section 144C(13), after the DRP issues its directions under Section 144C(5), the Assessing Officer is required to pass the final assessment order in conformity with those directions within one month from the end of the month in which such directions are received. This time-bound mandate is the operative trigger for finality of assessment in eligible cases, and compliance with the limitation period prescribed therein has been a recurring point of contest before appellate forums.

The 12 rulings

1. Servicenow Nederland Bv,Hyderabad vs ACIT, Circle Intl. Tax. 3(1)(2), Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 28 July 2026
Sections engaged: 10(50), 143(3), 144C(13), 153(1), 270A, 274
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed by the assessee against the order dated 14.01.2026 passed by the ACIT, Circle International Taxation-3(1)(2), Delhi, under section 143(3) read with section 144C(13) of the Income Tax Act for Assessment Year 2023-24. Per the source preview, a ground of appeal relates to the applicability of the Netherlands DTAA and an allegation that the Assessing Officer erred in assuming that there was a "make available" of technical knowledge by the appellant to the service recipient.

2. Rakesh Bhargava,Haryana vs Deputy Commissioner Of Income Tax

Bench: Income Tax Appellate Tribunal - Delhi
Date: 27 July 2026
Sections engaged: 120(3), 127(3), 143(3), 144C(13), 234, 54, 55(1)(ac)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was preferred by the assessee against the assessment order dated 28.08.2025 passed by the office of the ACIT/DCIT, International Taxation – Gurgaon, under section 143(3) read with section 144C(13) of the Income Tax Act, 1961, in pursuance of directions of the Dispute Resolution Panel-1, Delhi-3 dated 17.07.2025, pertaining to Assessment Year 2023-24. Per the source preview, a ground of appeal concerns valuation, with the assessee disputing the treatment of a valuation report of a registered valuer.

3. M/S. Informatica Llc,Bangalore vs Assistant Commissioner Of Income Tax

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 24 July 2026
Sections engaged: 115A, 143(3), 144C, 144C(13), 263, 9(1)(vi), 9(1)(vii)
Outcome: Outcome not specified in source
Procedural / substantive ground: Informatica LLC, a resident of the United States of America, filed this appeal for Assessment Year 2019-20 against the assessment order dated 27 January 2023 passed by the Assistant Commissioner of Income Tax, International Taxation Circle 1(2), Bengaluru. Per the source preview, the assessee's total income was determined at ₹53,34,48,706 as against the nil income declared in its return filed on 30 September 2019, and the assessment order was passed under section 143(3) read with section 144C(13) of the Income Tax Act.

4. Corteva Agriscience Services India vs DCIT., Circle 1(1), Hyderabad

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 22 July 2026
Sections engaged: 143(3), 144C(13), 144C(5), 153, 153B
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed as ITA 339/HYD/2025 for Assessment Year 2017-18. Per the source preview, in Ground No. 1 the assessee challenged the validity of the order passed by the Assessing Officer in pursuance of the DRP's directions, on the ground that the order was barred by limitation under the provisions of section 153(5A) of the Income Tax Act, 1961. The learned Authorised Representative's submissions on this limitation ground are referenced in the preview.

5. Global Analytics India Private vs DCIT, Circle 1(1), Chennai

Bench: Income Tax Appellate Tribunal - Chennai
Date: 21 July 2026
Sections engaged: 144C(13)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed as IT(TP)A No. 30/Chny/2026 for Assessment Year 2022-23. Per the source preview, the grounds of appeal include challenges relating to the selection and rejection of comparable companies for transfer pricing purposes, with the assessee contending incorrect inclusion and incorrect rejection of specific companies in the comparables set used for the benchmarking analysis.

6. Jones Lang Lasalle Property vs Deputy Commissioner Of Income

Bench: Income Tax Appellate Tribunal - Delhi
Date: 17 July 2026
Sections engaged: 143(2), 143(3), 144C(13), 154, 36(1), 36(1)(va), 43B
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was preferred by the assessee against the Final Assessment Order dated 25.02.2026 passed by the Assessment Unit, Income Tax Department, filed as IT(TP)A No. 218/Del/2026 for Assessment Year 2022-23. Per the source preview, the order records that the DRP order was dated 27.12.2025, the time limit under section 144C(13) to pass the final order (one month from the end of the month in which DRP directions were issued) expired on 31.01.2026, and the final assessment order was dated 25.02.2026 — indicating the limitation period was a live issue before the Tribunal.

7. M/S. Avaya India Pvt. Ltd.,Gurgaon vs Addl. CIT, New Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 16 July 2026
Sections engaged: 143(3), 144C(13), 144C(2), 144C(5), 43A, 92C
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed as ITA No. 1958/DEL/2017 for Assessment Year 2012-13. The source preview is primarily constituted by tabular asset-ledger data relating to transactions in FY 2011-12 and does not support further substantive observation beyond the appeal caption. The appeal was filed against the respondent Addl. CIT, Spl. Range 1, New Delhi, and the sections engaged include provisions relating to transfer pricing and the DRP final order mechanism.

8. Syniverse Technologies Services India vs ACIT, Circle-3(1), Gurgaon

Bench: Income Tax Appellate Tribunal - Delhi
Date: 10 July 2026
Sections engaged: 143(3), 144C, 144C(13), 153, 153A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed as ITA No. 2056/DEL/2022 for Assessment Year 2018-19. Per the source preview, the Revenue's Departmental Representative accepted on record that the intimation under section 144C(5) of the Act was passed on 05.05.2022 and the DRP order was dated 25.04.2022, with the preview referencing a corrigendum to the final assessment order — indicating that the sequence and timing of DRP and post-DRP proceedings was a material issue before the Tribunal.

9. Sudhakar Reddy Mettu vs Assistant Commissioner Of Income Tax

Bench: Telangana High Court
Date: 8 July 2026
Sections engaged: 142(1), 144C(13), 147, 148, 260A, 270A, 50C, 54F
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal under section 260A of the Income Tax Act, 1961 was filed before the Telangana High Court challenging the order passed by the Income Tax Appellate Tribunal, Hyderabad 'A' Bench in ITA No. 231/Hyd/2024, decided on 29.05.2024, wherein the ITAT upheld the decision of the Assistant Commissioner of Income Tax, International Taxation-1, and dismissed the appeal preferred by the appellant. Per the source preview, the assessee is an individual and non-resident Indian who had not filed a return of income for Assessment Year 2017-18, and the matter arose from immovable property transaction information disseminated by the I&CI wing for the Financial Year 2016-17 relevant to Assessment Year 2017-18.

10. DCIT., Circle 2(1), Hyderabad vs Tmeic Industrial Systems India Private

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 8 July 2026
Sections engaged: 144C, 144C(1), 144C(13), 144C(4), 153(1), 153(4), 254(2), 36(1)(va)
Outcome: Outcome not specified in source
Procedural / substantive ground: This proceeding was a Miscellaneous Application filed as MA No. 38/Hyd/2026 arising out of ITA No. 898/Hyd/2024 for Assessment Year 2020-21, filed by the Revenue under section 254(2) of the Income Tax Act, 1961, seeking recall or rectification of the Tribunal's earlier order on the ground that a mistake apparent from record existed in that order. Per the source preview, the Revenue's Departmental Representative drew attention to paragraph 12 of the impugned Tribunal order, contending that the Tribunal's holding on the limitation period was erroneous.

11. Ceragon Networks India Private vs DCIT, Circle-4(2), Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 8 July 2026
Sections engaged: 143(3), 144C, 144C(1), 144C(13)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed as ITA No. 5659/DEL/2024 for Assessment Year 2021-22. Per the source preview, the Assessing Officer passed the final assessment order dated 24.10.2024 without giving effect to the order passed under section 144C(5) of the Act, on the ground that he had not received the order giving effect from the TPO before passing the assessment order; however, the TPO had passed the order giving effect on 28.10.2024, and the Tribunal observed that the Assessing Officer should have passed the order giving effect on receipt of the OGE from the TPO within the limitation period prescribed under section 144C.

12. M/S. Triumph International Private vs DCIT, Corp Circle 3(1), Chennai

Bench: Income Tax Appellate Tribunal - Chennai
Date: 7 July 2026
Sections engaged: 144C, 144C(13), 153
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed as IT(TP)A No. 33/CHNY/2025 for Assessment Year 2020-21, and per the source preview the assessee filed this appeal against the final order. The preview also reflects a procedural inquiry by the Tribunal regarding the date on which the communication order was received by the Assessing Officer at NFAC, to which the response was that the information was not available with that office — indicating that the receipt and communication of DRP-related orders was a procedural point under examination.

Patterns across these 12 rulings

Limitation under Section 144C(13) is the most contested procedural ground. Multiple cases in this set — including cases 4, 6, 10, and 11 — directly raise the question of whether the Assessing Officer passed the final assessment order within the one-month window mandated after DRP directions. The Jones Lang Lasalle ruling (case 6) expressly records the DRP direction date, the computed limitation deadline, and the actual order date as distinct data points, indicating the Tribunal was squarely examining the timeliness of the final order.
International taxation circles and transfer pricing cases dominate the Section 144C(13) docket. Cases 1, 2, 3, 4, 5, 7, 8, and 9 involve taxpayers assessed by International Taxation circles (Delhi, Gurgaon, Hyderabad, Bengaluru, Chennai), reflecting that Section 144C(13) is operationally concentrated in the transfer pricing and non-resident assessment stream.
Miscellaneous Applications under Section 254(2) are being filed to re-agitate Section 144C limitation findings. Case 10 (DCIT vs. TMEIC Industrial Systems) demonstrates that where a Tribunal has made a finding on the limitation period under Section 144C, the Revenue has sought rectification of that finding by way of a Miscellaneous Application, suggesting that limitation-based holdings under Section 144C are themselves being challenged procedurally.
Multiple assessment years remain in active litigation simultaneously. The assessment years across these twelve rulings span from AY 2012-13 (case 7) to AY 2023-24 (cases 1 and 2), illustrating that Section 144C(13) disputes have protracted timelines and that old assessment years continue to generate fresh appellate proceedings.
The DRP directions–to–final order sequence is a distinct sub-issue across benches. Cases 8 and 11 both involve factual scrutiny of the precise dates of DRP directions, TPO orders, and final assessment orders, with the Syniverse case (case 8) noting the Revenue's own concession on relevant dates — suggesting that sequencing and timestamping of orders in the DRP process is a recurring evidentiary issue across different ITAT benches.

How to use this compilation

This compilation is organised as a research index and is not a substitute for reading the full text of each judgment. Each case entry sets out only the identity fields and a brief procedural or substantive note drawn from the source preview available in the TaxNoticeAI corpus. Because source previews are extracts and not complete orders, the full holdings, dispositive directions, and detailed reasoning in each case may extend significantly beyond what is reflected here. Researchers should obtain and read the complete judgment before citing any ruling in pleadings, opinions, or submissions.

Before relying on any ruling listed here, researchers should also verify whether the order has been stayed, reversed, remanded, or upheld by a superior forum. Several cases in this compilation are themselves appeals against earlier ITAT orders (e.g., case 9, which is a High Court appeal under Section 260A against an ITAT order), and the final position in any given matter may have changed after the date of the order listed. Parallel proceedings, rectification applications (as in case 10), and departmental appeals in the same matter should also be checked.

Finally, researchers should cross-reference the applicable CBDT instructions, circulars, and press notes on the operation of Section 144C and the DRP mechanism, as administrative guidance on timelines, eligible assessees, and procedural requirements may affect the interpretation of the statutory text. The limitation periods and procedural requirements under Section 144C have been the subject of CBDT clarifications from time to time, and any such guidance relevant to the assessment year in question should be considered alongside the case law indexed here.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 144C(13) Final Assessment Orders: 12 ITAT & HC Rulings (2026)