This compilation indexes twelve income-tax rulings — nine from the Income Tax Appellate Tribunal (ITAT) and three from High Courts — pronounced between December 2025 and June 2026, each engaging Section 144C of the Income Tax Act, 1961. The cases span multiple benches (Delhi, Mumbai, Chennai, Dehradun, Bombay High Court, Calcutta High Court, and Karnataka High Court) and cover procedural questions arising at every stage of the Section 144C pathway: draft assessment orders, Dispute Resolution Panel directions, and final assessment orders passed under Section 144C(13). The compilation is intended for in-house tax teams, Big-4 associates, and law-firm researchers who need a structured, citation-ready index of recent judicial activity on this provision.

Research index only. This page is a structured case-law reference. Nothing on this page constitutes legal or tax advice. Readers must independently verify each ruling against the full judgment text, check for any subsequent stays or reversals, and consult qualified advisers before acting on any legal position.

The statutory framework in one paragraph

Section 144C of the Income Tax Act, 1961 prescribes a special procedure applicable to "eligible assessees" — a category that includes foreign companies and entities in respect of which a transfer-pricing adjustment has been proposed — before any variation prejudicial to the assessee can be made in a final assessment order. Under the provision, the Assessing Officer is first required to pass a draft assessment order and forward it to the eligible assessee. The assessee may then either accept the variation or file objections before the Dispute Resolution Panel (DRP). The DRP issues directions under Section 144C(5), and the Assessing Officer is thereafter required to pass a final assessment order in conformity with those directions, which order is treated as passed under Section 144C(13). The provision is designed to provide an additional layer of procedural protection to eligible assessees before a final demand is crystallised.

The 12 rulings

1. Macquarie Sbi Infrastructure vs Assistant Commissioner Of Income Tax

Bench: Income Tax Appellate Tribunal - Delhi
Date: 15 June 2026
Sections engaged: 143(2), 143(3), 144C, 144C(13), 153, 234A, 234B, 270A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed by the assessee against the final assessment order dated 26.07.2023 passed by the ACIT, Circle Int. Tax- 2(2)(1), New Delhi under Section 143 read with Section 144C(13), pursuant to the directions of the Dispute Resolution Panel-2, New Delhi, for Assessment Year 2020-21. The ITA number on record is ITA No. 2667/Del/2023; the source preview does not disclose the substantive grounds resolved by the Tribunal beyond identifying the appeal as arising from the DRP-directed final assessment order.

2. Marriott International Innc ,Mumbai vs DCIT (International Taxation) 3(2)

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 8 June 2026
Sections engaged: 139(1), 143(3), 144C, 144C(1), 144C(3), 153, 156, 271(1)(c), 274
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed before the ITAT Mumbai "I" Bench covering Assessment Years 2013-14 and 2014-15, registered as ITA No. 1622 & 1623/Mum/2021. The source preview records that the Tribunal considered certain case-law citations in the course of deciding the matter; the full substantive reasoning is not disclosed in the available preview, and no specific finding can be reported without reference to the complete judgment text.

3. Assistant Commissioner Of Income Tax vs Transworld Garnet India Private

Bench: Income Tax Appellate Tribunal - Chennai
Date: 4 May 2026
Sections engaged: 144C, 292B
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal was filed by the Revenue before the ITAT Chennai 'B' Bench, registered as ITA No. 4142/CHNY/2025, directed against the order dated 17.10.2025 passed by the Commissioner of Income Tax (Appeals)-19, Chennai, which itself arose from the assessment order dated 30.03.2024 passed by the Deputy Commissioner of Income Tax, Central Circle-2, Madurai, for Assessment Year 2018-19. The source preview does not reveal the substantive findings of the Tribunal beyond confirming the procedural chain of orders.

4. Schlumberger Solutions Pvt vs ITO, Ward- 2(4), Dehradun

Bench: Income Tax Appellate Tribunal - Dehradun
Date: 10 April 2026
Sections engaged: 144C
Outcome: Outcome not specified in source
Procedural / substantive ground: The assessee's appeal for Assessment Year 2013-14, registered as ITA No. 5557/Del/2017, arose against the Income Tax Officer, Ward-2(4), Dehradun's assessment order dated 30.06.2017, framed pursuant to the Dispute Resolution Panel, New Delhi's directions in objections no. 315/16-17 dated 28.04.2017, involving proceedings under Section 144C of the Act. The source preview indicates that the assessee was aggrieved by the action of the lower authorities in relation to an arm's length price determination; the Tribunal's resolution of that issue is not disclosed in the available preview text.

5. The Dy CIT, Circle-4(1)(2), Ahmedabad vs M/S. Vodafone West Ltd., Ahmedabad

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 2 April 2026
Sections engaged: 144C, 143(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: These cross-appeals before the ITAT Mumbai "J" Bench, registered as ITA No. 443/Ahd/2016 and ITA No. 571/Ahd/2016, were directed against the final assessment order dated 08.02.2016 for Assessment Year 2011-12. The assessee is identified in the source preview as Vodafone Idea Limited (formerly known as Vodafone West Limited), PAN AAACF1190P. The source preview does not disclose the substantive findings on the grounds arising under Section 144C beyond confirming the cross-appeal structure and the relevant assessment year.

6. Hansgrohe India Private Limited vs The Assessment Unit Income Tax Dept And

Bench: Bombay High Court
Date: 25 March 2026
Sections engaged: 144B, 144C
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WP No. 3501 of 2026) challenged the final assessment order dated 2nd February 2026 for Assessment Year 2023-24. The petitioner's core grievance, as recorded in the source preview, was that it qualified as an "eligible assessee" within the meaning of Section 144C(15)(b)(i) of the Act, and therefore the Assessing Officer was obliged to first pass a draft assessment order and serve it on the petitioner to enable it to file objections before the Dispute Resolution Panel, before any final order prejudicial to the assessee could be passed.

7. Almatis Alumina Private Limited vs Assistant/Deputy Commissioner Of

Bench: Calcutta High Court
Date: 19 March 2026
Sections engaged: 144C, 144C(13)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petitioner had filed its return of income for Assessment Year 2017-18 declaring total income as nil under the normal provisions and reporting a book loss of Rs. 21,34,14,840 under Section 115JB. The Assessing Officer referred certain international transactions with associated enterprises to the Transfer Pricing Officer, who proposed an adjustment of Rs. 41,13,22,617 to the petitioner's income; since this proposed adjustment resulted in a variation prejudicial to the assessee, the source preview records that the special procedure under Section 144C became applicable. The writ petition (W.P.O. No. 284 of 2024) was filed before the Calcutta High Court engaging Section 144C and Section 144C(13).

8. Principal Commissioner Of Income Tax-1 vs Boeing India Pvt. Ltd

Bench: Delhi High Court
Date: 16 March 2026
Sections engaged: 144C, 143(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA 586/2025) was filed by the Revenue before the Delhi High Court under Section 260A of the Act against the ITAT's judgment dated 27.03.2024 in ITA No. 828/Del/2021, whereby the ITAT had allowed the appeal in favour of Boeing India Pvt. Ltd. Per the source preview, the ITAT had relied upon the Supreme Court's decision in PCIT v. Maruti Suzuki (2020) 18 SCC 331 and a coordinate bench judgment of the Delhi High Court in CIT v. Sony Mobile Communications India Pvt. Ltd. 2023/DHC/001366, holding that the final assessment order dated 30.03.2021 was affected by the procedural requirements of Section 144C; the High Court's own resolution of the Revenue's appeal is not disclosed in the available preview text.

9. Ge Engine Services Llc,United States Of vs Assistant Commissioner Of Income Tax

Bench: Income Tax Appellate Tribunal - Delhi
Date: 11 March 2026
Sections engaged: 143(3), 144C
Outcome: Taxpayer succeeded
Procedural / substantive ground: The assessee's appeal (ITA No. 3700/Del/2023) for Assessment Year 2021-22 was directed against the Final Assessment Order passed under Section 143(3) read with Section 144C(13) dated 20.10.2023, pursuant to the Dispute Resolution Panel's directions dated 13.09.2023. Ground No. 1 of the appeal challenged the assessment order as bad in law on the basis that it was passed under Section 143(3) read with Section 144C of the Act; the source preview further indicates that the appeal involved arguments concerning the denial of treaty benefits under the India-US DTAA, and the outcome is recorded as the taxpayer having succeeded.

10. Archroma International (India) vs Deputy Commissioner Of Income Tax

Bench: Bombay High Court
Date: 22 December 2025
Sections engaged: 143(2), 144C, 92C
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WP(L) No. 11219 of 2025) was filed under Article 226 of the Constitution of India before the Bombay High Court for Assessment Year 2009-10, challenging the inaction of the respondents. The source preview records that during the pendency of the writ petition, Respondent No. 1 passed an order dated 15th September 2025 disposing of a rectification application dated 14th June 2016, which resulted in a refund of Rs. 4,17,04,918, credited to the petitioner's bank account on 18th December 2025; the petitioner indicated it had not been able to verify the correctness of that amount at the time of hearing.

11. Zynga Game Network India Private vs Assement Unit / Income Tax Officer

Bench: Karnataka High Court
Date: 16 December 2025
Sections engaged: 143(3), 144C
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WP No. 4398 of 2023) was filed before the Karnataka High Court under Articles 226 and 227 of the Constitution of India, praying to quash the impugned final assessment order dated 20/12/2022 passed by Respondent No. 1 under Section 143(3) read with Section 144C of the Act. The source preview confirms the petition's relief sought and the identity of the petitioner as Zynga Game Network India Private Limited (PAN: AAACZ3937G); the High Court's substantive findings are not disclosed in the available preview text.

12. Hitachi Energy India Limited vs Deputy Commissoner Of Income Tax

Bench: Karnataka High Court
Date: 16 December 2025
Sections engaged: 144C, 144C(15)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WP No. 18110 of 2024) was filed before the Karnataka High Court under Article 226 of the Constitution of India, praying to quash the draft assessment order bearing DIN ITBA/AST/F/144C/2023-24/1056676734(1) dated 29.09.2023 passed by the Deputy Commissioner of Income Tax under Section 144C of the Act for Assessment Year 2020-21, as non-est and void ab initio. The petitioner — Hitachi Energy India Limited (formerly known as ABB Power Products and Systems India Limited) — thus challenged the draft order itself at the pre-DRP stage, engaging the definition of "eligible assessee" under Section 144C(15)(b).

Patterns across these 12 rulings

Mandatory draft-order requirement for eligible assessees. At least three rulings in this set (Hansgrohe India, Zynga Game Network, and Hitachi Energy India) centre on the foundational procedural requirement that an Assessing Officer must issue a draft assessment order to an eligible assessee before passing any final order involving a variation prejudicial to the assessee. Challenges to the omission or defective issuance of this draft order recur across ITAT and High Court jurisdictions.
DRP-directed final orders as the trigger for ITAT appeals. The majority of ITAT appeals in this compilation — including Macquarie SBI Infrastructure, GE Engine Services, and Schlumberger Solutions — arise specifically from final assessment orders passed pursuant to DRP directions, confirming that the DRP-to-ITAT appellate pathway under Section 144C(13) is an active and heavily litigated route.
International taxation and transfer pricing as the dominant context. Cases involving foreign companies or entities with international transactions (Macquarie SBI, GE Engine Services, Marriott International, Almatis Alumina, Boeing India, Schlumberger Solutions, Vodafone West) form the bulk of this compilation. This reflects the statutory design of Section 144C, which was specifically introduced to address transfer-pricing and international-tax assessments.
High Court writ jurisdiction as an alternative to the DRP route. Several petitioners — including Hansgrohe India (Bombay HC), Almatis Alumina (Calcutta HC), Zynga Game Network (Karnataka HC), Hitachi Energy India (Karnataka HC), and Archroma International (Bombay HC) — chose to challenge assessment orders or draft orders directly by way of writ petitions rather than exhausting the DRP/ITAT pathway. This signals continued litigant willingness to invoke constitutional jurisdiction where procedural violations under Section 144C are alleged.
Precedent reliance on Supreme Court and coordinate-bench judgments. The Boeing India ruling before the Delhi High Court illustrates that ITAT and High Court benches are actively applying the Supreme Court's decision in PCIT v. Maruti Suzuki (2020) 18 SCC 331 to Section 144C fact patterns, and the Revenue's attempt to reopen that question at the High Court level confirms that the legal position on mandatory draft-order requirements remains a live area of appellate activity.

How to use this compilation

This index is organised chronologically in descending order of date of pronouncement (June 2026 to December 2025) and covers ITAT and High Court orders. Each entry provides the minimum identity fields needed to locate the full judgment: bench, date, ITA or writ petition number (where disclosed in the source preview), and the sections engaged. Researchers should treat this compilation as a starting point for locating relevant rulings and should retrieve the full judgment text from indiankanoon.org, the official ITAT e-filing portal, or the relevant High Court's official portal before citing any ruling in a legal submission or memorandum.

Before relying on any ruling listed here, practitioners should verify whether the order has been stayed, reversed, or modified by a superior court. High Court and ITAT orders are subject to further appeal: ITAT orders may be appealed to the relevant High Court under Section 260A, and High Court orders may be taken to the Supreme Court. Additionally, the CBDT periodically issues circulars, instructions, and clarifications that may affect the interpretation of Section 144C; these departmental materials should be checked in parallel with case-law research.

The source previews available for several cases in this compilation are limited to introductory paragraphs and procedural recitals. Where the available text does not disclose the Tribunal's or Court's substantive findings, the "Procedural / substantive ground" entry for that case reflects only what the source text supports. Researchers requiring full analysis of those cases should access the complete judgment text before drawing conclusions about the legal position adopted by the forum.

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 Draft Assessment & DRP Procedure: 12 Rulings (2025–2026)