Section 263 Cannot Override DRP: ITAT Mumbai Quashes Revision

Mondelez India Foods Private Limited Vs PCIT (ITAT Mumbai) In this case, the ITAT Mumbai quashed the revision order passed under Section 263, holding that once an assessment is completed pursuant to directions issued by the Dispute Resolution Panel (DRP) under Section 144C, such an order cannot be revised by the PCIT. The Tribunal emphasized that the DRP is a collegium of three Commissioners and functions as a high-level corrective mechanism within the assessment process. When the Assessing Officer passes the final order strictly in conformity with DRP directions, there is no scope to treat su...