Tribunal held that it is the duty of the Dispute Resolution Panel to decide the issues raised by the assessee before it dealing with all the contentions of the assessee. Since this had not been done the entire matter was remanded for the assessment year 2006-07 to the Panel with the direction to pass a reasoned and speaking order dealing with all the contentions of the assessee. The Panel was to afford a reasonable opportunity of being heard to the assessee. ( AY.2006 -07)
Cengage Learning India Pvt. Ltd. v. ITO (2018) 65 ITR 374 (Delhi) (Trib)
S. 144C : Reference to dispute resolution panel -Transfer pricing- Duty of DRP to decide issues raised by assessee- DRP is directed to pass a reasoned and speaking order dealing with all contentions of assessee after giving reasonable opportunity to assessee.