ValkyaEditorial

Tagged “dispute-resolution-panel”

1 article on dispute-resolution-panel.

High CourtHigh Court of Delhi

PCIT v. Borgwarner Emissions Systems (2025): the DRP must apply its own mind

In December 2025 a Division Bench of the Delhi High Court dismissed the Revenue's transfer-pricing appeal, faulting the Dispute Resolution Panel for merely endorsing the Transfer Pricing Officer's conclusions without recording its own findings. A digest of the facts, the statutory duty of the DRP under Section 144C, and why the Court found no substantial question of law.

Valkya Editorial··7 min