Section 144C → Section 164
Dispute Resolution Panel (DRP)
Quick Answer
Section 144C of the Income Tax Act, 1961 (Dispute Resolution Panel (DRP)) corresponds to Section 164 of the Income-tax Act, 2025, effective 1st April 2026. Status: Retained.
What changed for Section 144C
Section 144C of the 1961 Act sets out the rules on dispute resolution panel (DRP). An alternative dispute resolution mechanism for foreign companies and Transfer Pricing cases.
The new code maps this to Section 164: the provision is retained and renumbered as Section 164 of the Income-tax Act, 2025, applying from 1st April 2026. Retained. Eligible assessees can approach DRP against a 'Draft Assessment Order' before the final order is passed.
On the ground, changes to Section 144C carry a High impact. Crucial for MNCs to avoid long-drawn litigation in CIT(A).
Sec 144C
Provision Summary
An alternative dispute resolution mechanism for foreign companies and Transfer Pricing cases.
Sec 164
Provision Summary
Retained. Eligible assessees can approach DRP against a 'Draft Assessment Order' before the final order is passed.
Key Changes & Highlights
- Timelines for DRP directions strictly enforced to 9 months.
Related Sections
Frequently Asked Questions
What does Section 144C of the Income Tax Act 1961 deal with?
Section 144C of the Income Tax Act, 1961 covers dispute resolution panel (DRP). An alternative dispute resolution mechanism for foreign companies and Transfer Pricing cases.
Where does Section 144C of the ITA 1961 go under the Income-tax Act, 2025?
Section 144C of the Income Tax Act, 1961 maps to Section 164 of the Income-tax Act, 2025, effective 1st April 2026 (status: Retained). Retained. Eligible assessees can approach DRP against a 'Draft Assessment Order' before the final order is passed.
Why does the change to Section 144C matter for taxpayers?
The transition impact for Section 144C is rated High. Crucial for MNCs to avoid long-drawn litigation in CIT(A).
What are the key changes to Section 144C under the Income-tax Act, 2025?
Timelines for DRP directions strictly enforced to 9 months. These points are specific to Section 144C (Dispute Resolution Panel (DRP)).
Disclaimer: This mapping of Section 144C (Dispute Resolution Panel (DRP)) to Section 164 of the Income-tax Act, 2025 is for educational and reference purposes only, based on publicly available drafts and circulars. As Section 144C is currently marked Retained, always confirm its treatment with a qualified Chartered Accountant before filing or making compliance decisions.
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