https://www.taxtmi.com/caselaws?id=768112 ITAT Chennai held that DRP lacks jurisdiction under section 144C to direct TPO or AO in second round proceedings after ITAT set-aside, when AO had already passed final assessment order under section 143(3) read with section 144C(3). The tribunal ruled that DRP derives powers from section 144C and Income-tax (Dispute Resolution Panel) Rules, 2009, which do not expressly grant such authority for second round directions. Relying on Bombay HC precedent in Undercarriage and Tractor Parts case, ITAT concluded DRP can only give directions in pending assessment proceedings, not after assessment completion. Consequently, transfer pricing order under section 92CA(3) and final assessment order under section 143(3) read with section 144C(5) were declared void ab-initio and quashed. en-us Mon, 24 Feb 2025 00:00:00 +0530 Tue, 01 Apr 2025 08:31:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768112 ITAT Chennai held that DRP lacks jurisdiction under section 144C to direct TPO or AO in second round proceedings after ITAT set-aside, when AO had already passed final assessment order under section 143(3) read with section 144C(3). The tribunal ruled that DRP derives powers from section 144C and Income-tax (Dispute Resolution Panel) Rules, 2009, which do not expressly grant such authority for second round directions. Relying on Bombay HC precedent in Undercarriage and Tractor Parts case, ITAT concluded DRP can only give directions in pending assessment proceedings, not after assessment completion. Consequently, transfer pricing order under section 92CA(3) and final assessment order under section 143(3) read with section 144C(5) were declared void ab-initio and quashed. Case-Laws Income Tax Mon, 24 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768112