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Government of India
F. No. 500/1212013-SOIFT&TR-2(1) New Delhi, dated 13"' August, 2014 ORDER No. 2/FT&TR/2014 In exercise of the powers conferred by clause (a) of sub-section (15) of section 144C of the Income-tax Act,1961 (43 of 1961) read with Income-tax (Dispute Resolution Panel) Rules, 2009 as amended from time to time and in supersession of earlier orders constituting Dispute Resolution Panels at Mumbai and Pune, the Central Board of Direct Taxes hereby constitutes the Dispute Resolution Panels at Mumbai and Pune comprising of three Commissioners of Income-tax as Members of the said Panels with a Reserve Member in each Panel in accordance with Rule 3{3) of the Income-tax (Dispute Resolution Panel) Rules, 2009 as under:
2.
(Rajat Bansal)
***end*** What is Dispute Resolution Panel (DRP)? Section 144C of the Income Tax Act 1961, inserted by the Finance (No.2) Bill, 2009, w.e.f. 01-10-2009 contains the provisions related to Dispute Resolution Panel. Minister of Finance, Shri Pranab Mukherjee while delivering Budget 2009-10 speech explained the objectives of DRP as under; “in order to further improve the investment climate in the country, we need to facilitate the resolution of tax dispute faced by foreign companies within a reasonable time frame. This particularly relevant for such companies in the Information Technology (IT) sector. I therefore, propose to create an alternative dispute resolution meachanism within the Income Tax Department for the resolution of transfer pricing disputes. To reduce the impact of judgemental errors in determining transfer pricing in international transactions, it is proposed to empower the Central Board of Direct taxes(CBDT) to formulate ‘safe harbour’ rules.” Dispute Resolution Panel (DRP ) is a collegium comprising three commissioners of Income Tax constituted by CBDT to hear the dispute related to transfer pricing between assessee and the Assessing Officer. An assessee who objects to the assessment order passed by the AO can file an objection with the panel. DRP is authorized to issue appropriate directions for the guidance of Assessing Officer. |