This compilation indexes twelve income-tax rulings — spanning the Income Tax Appellate Tribunal (ITAT) benches at Mumbai, Bangalore, Hyderabad, and Delhi, as well as the Bombay High Court and Punjab-Haryana High Court — in which Section 144C(5) of the Income-tax Act, 1961 was engaged. The cases range from December 2025 to August 2026 and arise predominantly in the context of final assessment orders passed pursuant to Dispute Resolution Panel (DRP) directions. This index is intended for in-house tax teams, Big-4 associates, and law firm researchers who track DRP-linked assessment proceedings and related appellate activity.

Research index only. This page catalogues judicial proceedings for reference purposes. Nothing on this page constitutes legal advice, tax advice, or a recommendation of any course of action. Readers must consult qualified legal counsel and verify all information against the full text of the original judgments.

The statutory framework in one paragraph

Section 144C of the Income-tax Act, 1961 establishes the reference procedure to the Dispute Resolution Panel for eligible assessees, which include foreign companies and those in whose case a transfer pricing adjustment has been proposed. Under sub-section (1), the Assessing Officer is required to forward a draft assessment order to the eligible assessee before passing the final order. Sub-section (5) specifically governs the Dispute Resolution Panel's obligation to issue directions to the Assessing Officer after considering the objections filed by the assessee, and it prescribes the timelines within which such directions must be issued. The final assessment order is thereafter required to be passed by the Assessing Officer in conformity with the directions issued under sub-section (5), as governed by sub-section (13). The interplay between sub-sections (1), (5), and (13), and the limitation provisions that attach to the DRP-directed assessment process, has generated a substantial and growing body of appellate jurisprudence across ITAT benches and High Courts.

The 12 rulings

1. Ucweb Mobile Private Ltd vs Assessment Unit, Income Tax Department

Bench: Punjab-Haryana High Court
Date: 7 August 2026
Sections engaged: 143(2), 143(3), 144C(1), 144C(10), 144C(15)(b), 144C(2), 144C(3), 144C(5), 156, 270A, 274, 92C
Outcome: Outcome not specified in source
Procedural / substantive ground: The petitioner filed Civil Writ Petition No. 4329 of 2024 before the Punjab-Haryana High Court challenging the final assessment order dated 15.12.2023 pertaining to the assessment year 2021-22, passed under Section 143(3) read with Section 144C(3) of the Income-tax Act. The petition was reserved for judgment on 07.07.2026 and the full judgment was pronounced on 07.08.2026; per the source preview, this was a speaking and reasoned order of the court.

2. Indus Valley Partners (India) Private vs The Deputy Commissioner Of Income Tax

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 29 July 2026
Sections engaged: 115J, 143(3), 144B, 144C(1), 144C(5), 170A, 92C
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 6243/Mum/2024) was directed against the final assessment order dated 22.10.2024 passed under Section 143(3) read with Section 144C(13) read with Section 144B of the Act for Assessment Year 2021-22, pursuant to directions issued by the Dispute Resolution Panel-1, Mumbai under Section 144C(5) of the Act dated 30.09.2024; the draft assessment order had been passed on 22.12.2023 under Section 144C(1) of the Act, per the source preview.

3. Kore.Ai Software India Private vs ITO, Ward- 2(1),, Hyderabad

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 29 July 2026
Sections engaged: 144C(5), 270A
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 51/HYD/2026) was filed by the assessee against the final assessment order passed under Section 143(3) read with Sections 144C(13) and 144B of the Act pursuant to the directions of the Dispute Resolution Panel for Assessment Year 2022-23 dated 14.11.2025. Among the grounds raised, the assessee contended that its case does not qualify under any reasons prescribed by Section 270A for levy of such penalty, per the source preview.

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: This appeal (ITA 339/HYD/2025) concerned Assessment Year 2017-18. In Ground No. 1, the assessee challenged the validity of the order passed by the Assessing Officer in pursuance of the DRP's directions as being barred by limitation under the provisions of Section 153 of the Income-tax Act, per the source preview; the hearing concluded on 14.07.2026 and the order was pronounced on 22.07.2026.

5. Marlabs Innovations Private vs DCIT, Circle 4(1)(1) - Bangalore

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 8 June 2026
Sections engaged: 144C(5), 144C(13)
Outcome: Outcome not specified in source
Procedural / substantive ground: The assessee filed this appeal (ITA No. 833/Bang/2026) against the final assessment order dated 18.12.2025 passed under Section 143(3) read with Section 144C(13) read with Section 144B of the Act, pursuant to the directions issued by the Dispute Resolution Panel-2, Bangalore under Section 144C(5) of the Act, for Assessment Year 2022-23, per the source preview. The learned Authorised Representative raised a submission at the outset of the hearing regarding the impugned final assessment order, though the substantive ground is not further detailed in the available preview.

6. Bunteler Automotive India Pvt. Ltd vs The Union Of India Thr The Secretary

Bench: Bombay High Court
Date: 21 April 2026
Sections engaged: 144C(1), 144C(5), 144C(13)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petitioner, a manufacturer of automotive fasteners and connectors whose share capital is held by German and Austrian entities, filed Writ Petition No. 10391 of 2022 before the Bombay High Court. Per the source preview, the petition was disposed of finally with the consent of counsel for both sides, with the court issuing Rule returnable forthwith; the matter concerned, among other things, a transfer pricing reference following a return filed on 27.11.2016 disclosing income for Assessment Year 2016-2017 as 'Nil', and a notice under Section 143(2) dated 01.08.2017, with the case subsequently transferred to the Transfer Pricing Officer.

7. The Pr. Commissioner Of Income Tax -4 vs Tetra Pak India Pvt. Ltd

Bench: Bombay High Court
Date: 12 March 2026
Sections engaged: 144C(1), 144C(5)
Outcome: Outcome not specified in source
Procedural / substantive ground: This Income Tax Appeal No. 2551 of 2018 was filed before the Bombay High Court by the Principal Commissioner of Income Tax against Tetra Pak India Pvt. Ltd., a company engaged in manufacturing and selling packaging machines, systems, and spare parts. Per the source preview, the assessee had entered into various international transactions with its Associate Enterprises during the assessment year under appeal, following which the case was referred to the Transfer Pricing Officer, who proposed an outward transfer pricing adjustment of Rs. 7,47,09,000/- under Section 92CA(3) of the Act.

8. M/S. Ntt Data Global Services Private vs The Joint Commissioner Of Income Tax

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 23 February 2026
Sections engaged: 144C(5)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (IT(TP)A No. 2533/Bang/2019) pertained to Assessment Year 2015-2016, with hearing concluded on 25.11.2025 and the order pronounced on 23.02.2026. Per the source preview, the order involved a comparative analysis of potential comparable companies in the context of the transfer pricing dispute, with certain companies being rejected on grounds such as the persistent loss filter and export revenue to sales filter, while others were accepted on the basis of functional and asset profile similarity.

9. Srf Limited,New Delhi vs ACIT, Circle-10(1), Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 12 December 2025
Sections engaged: 10B(2), 115A, 143(1), 143(3), 144C(13), 144C(5), 156, 17, 25, 260, 28, 34
Outcome: Outcome not specified in source
Procedural / substantive ground: Three appeals were clubbed in this matter: ITA No. 1448/Del/2022 for Assessment Year 2017-18, ITA No. 1449/Del/2022 for Assessment Year 2018-19, and ITA No. 5618/Del/2024 for Assessment Year 2021-22, all filed by SRF Limited (PAN: AAACS0206P) against the ACIT, Circle 10(1), Delhi. Per the source preview, ITA No. 1448/Del/2022 was filed against the assessment order dated 29.04.2022 passed under Section 143(3) read with Section 260 of the Income-tax Act; hearing was conducted on 15.10.2025 and the order was pronounced on 12.12.2025.

10. Mahua Bharatpur Expressways Limited vs DCIT, Circle-5(1), Hyderabad

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 12 December 2025
Sections engaged: 144C(5), 270A
Outcome: Outcome not specified in source
Procedural / substantive ground: This matter (ITA TP No. 170/Hyd/2022) concerned Assessment Year 2017-18 and was heard together with connected appeals of M/s Western UP Tollway Limited (ITA TP Nos. 67/Hyd/2022 and 493/Hyd/2022). Per the source preview, the order references circumstances in which a notice may be challenged — including where a notice is issued beyond the period of limitation, without authority, without following prescribed procedures, or with a prejudiced mind — indicating that procedural validity was a ground in issue before the bench.

11. Interwrap Corp Private Limited vs DCIT., Circle -5(1), Hyderabad

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 10 December 2025
Sections engaged: 143(3), 144C(5)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (I.T.A. No. 496/Hyd/2022) was filed by the assessee — Interwrap Corp Private Ltd, successor of Owens Corning Industries (India) Private Limited — against the final assessment order dated 28.07.2022 passed under Section 143(3) read with Section 144C(13) read with Section 144B of the Act, for Assessment Year 2018-19, in pursuance of DRP directions, per the source preview. The hearing concluded on 03.12.2025 and the order was pronounced on 10.12.2025.

12. Adp Private Limited,Hyderabad vs DCIT., Circle 1(1), Hyderabad

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 10 December 2025
Sections engaged: 144C(5), 92C
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (I.T.A. No. 332/Hyd/2025) was filed against the final assessment order dated 06.12.2024 passed under Section 143(3) read with Section 144C(13) read with Section 144B of the Act, in pursuance of the directions dated 27.09.2024 of the Dispute Resolution Panel-1, Bengaluru, passed under Section 144C(5) of the Act, pertaining to Assessment Year 2021-22, per the source preview. The assessee's PAN is AANCA8983A and the hearing concluded on 03.12.2025.

Patterns across these 12 rulings

DRP directions as the trigger for appellate proceedings. Across the majority of these cases, the final assessment order challenged before the ITAT or High Court was passed pursuant to directions issued by the Dispute Resolution Panel under Section 144C(5). The DRP-direction-to-final-order pipeline under Sections 144C(5) and 144C(13) is the common procedural spine connecting cases 2, 3, 4, 5, 11, and 12 in this compilation.
Transfer pricing as the underlying substantive context. Section 92C appears in the sections lists for cases 1, 2, and 12, and the text previews for cases 6, 7, and 8 reference Transfer Pricing Officer proceedings and comparable company analyses. This indicates that Section 144C(5) directions in this corpus predominantly arise in the context of international transactions and transfer pricing adjustments involving foreign-owned or multinational entities.
Limitation as a contested ground. Case 4 (Corteva Agriscience) explicitly identifies limitation under Section 153 as Ground No. 1, and case 10 (Mahua Bharatpur Expressways) references a framework for challenging notices on limitation and procedural grounds. This recurring theme suggests that the permissible timeframe within which assessment orders must be passed following DRP directions is a live and frequently litigated question.
Penalty under Section 270A raised alongside Section 144C(5) proceedings. Cases 3 (Kore.Ai Software) and 10 (Mahua Bharatpur Expressways) both list Section 270A in their sections engaged, with case 3's preview specifically noting a ground that the assessee's case does not qualify for penalty under Section 270A. This indicates that penalty levy is being raised as a collateral ground in DRP-linked final assessment proceedings.
Geographic spread of ITAT adjudication. The 12 rulings span ITAT benches at Hyderabad (cases 3, 4, 10, 11, 12), Bangalore (cases 5, 8), Mumbai (case 2), and Delhi (case 9), as well as the Bombay High Court (cases 6, 7) and Punjab-Haryana High Court (case 1). This geographic spread reflects the broad applicability of Section 144C(5) proceedings to eligible assessees across India's major jurisdictions.

How to use this compilation

This compilation is a starting-point index, not a substitute for reading the full text of each judgment. Each case entry above is drawn from structured metadata and text previews; the source preview for most entries covers only the opening paragraphs of the order, meaning that the substantive holdings, final disposals, and detailed reasoning of the tribunals and courts are not fully reflected here. Researchers should retrieve the complete order from indiankanoon.org, the official court portal, or a licensed legal database before relying on any entry for professional purposes.

Before treating any ruling as precedent or authority, researchers should also verify whether the order has been appealed, stayed, or reversed by a higher forum. An ITAT order may be the subject of a pending High Court appeal, and a High Court ruling may be under challenge before the Supreme Court. Checking the current status of each proceeding — including any interim stay of demand under Section 156 or any stay of the DRP-directed assessment order — is an essential step that this index cannot perform on the reader's behalf.

Finally, researchers should check for any CBDT circulars, instructions, or notifications that may affect the application of Section 144C(5) in a given fact pattern, including instructions relating to faceless assessment procedures, DRP timelines, and eligible assessee categories. Statutory provisions and procedural rules in this area have been amended over time, and the assessment year to which a ruling relates may affect its relevance to a current matter.

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(5) DRP Directions: 12 Income-Tax Rulings (2025–2026)