Assessment Quashed for Ignoring Binding DRP Directions

Bechtel Limited Vs ACIT (ITAT Delhi) DRP Directions Are Binding: Delhi ITAT Quashes Bechtel Assessments for Ignoring ‘Protective Basis’ Mandate Delhi ITAT ‘D’ Bench in Bechtel Limited, UK Vs. ACIT  [ITA No. 1816/Del/2022, AY 2018-19 & ITA No. 756/Del/2023, AY 2020-21, order dated 31.12.2025] quashed final assessment orders as void ab initio for non-adherence to binding directions of DRP u/s 144C. Assessee, a UK tax resident, had rendered engineering & procurement support services to Reliance Industries Ltd. and claimed receipts as non-taxable in India in absence of PE and “m...