Trivium Esolutions Pvt. Ltd. v. Dy. CIT (2022) 99 ITR 27 (SN) (Bang.)(Trib.)

S. 144C : Reference to dispute resolution panel-Arm’s length price-Transfer pricing adjustment was not in accordance with the direction of the Dispute Resolution Panel-Order was quashed. [S. 144C(13)]

Held that the final order of assessment the Assessing Officer retained the same transfer pricing adjustment as in the draft assessment order merely because the Transfer Pricing Officer had not passed the order giving effect to the directions of the Dispute Resolution Panel and considering the time-limit for passing the final assessment order. This would mean that the final assessment order passed by the Assessing Officer was not in accordance with the directions of the Dispute Resolution Panel. The assessment framed in this case was  quashed.(AY.2017-18)