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 Direct Tax Code 2025 (Income-tax Act, 2025), effective 1st April 2026. Status: Retained.
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 (Dispute Resolution Panel (DRP)) An alternative dispute resolution mechanism for foreign companies and Transfer Pricing cases.
What is the new section number for Section 144C under the Direct Tax Code 2025?
Section 144C of the ITA 1961 maps to Section 164 of the Direct Tax Code 2025 (Income-tax Act, 2025), effective from 1st April 2026.
What is the status of Section 144C under the new tax code?
Section 144C is marked as "Retained" with status "Active". Impact: High - Crucial for MNCs to avoid long-drawn litigation in CIT(A).
What are the key changes to Section 144C under DTC 2025?
Timelines for DRP directions strictly enforced to 9 months.
Disclaimer: This page is for educational and reference purposes only. Section mappings are based on publicly available drafts and circulars. Always consult a qualified Chartered Accountant before filing or making compliance decisions under the Direct Tax Code 2025.
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