Delphi-TVS Diesel Systems Ltd. v. ITO (2021) 323 CTR 508 / 207 DTR 329/ ( 2022) 440 ITR 310 / 286 Taxman 144 (Mad.)(HC)

S. 144C : Reference to dispute resolution panel-Power of enhancement-Any matter relating to assessment-Writ was dismissed. [S.92C, 144C(8), Art, 226]

Dismissing the petition the Court held that DRP being a specialised Panel is provided with power to propose variations relating to any matter arising out of assessment proceedings and Explanation to sub-section (8) of section 144C stipulates that enhancement is to be made with reference to matter arising out of assessment proceedings relating to draft assessment order. Court also held that  there is no impediment as such for DRP to consider any matter arising out of assessment proceedings relating to draft assessment order and no matter, such an issue was discussed in draft assessment order or not, but it should not be totally unconnected with assessment proceedings or draft assessment order.  (AY. 2013-14)