Journal Press India^®

Author Details ( * ) denotes Corresponding author

The dispute resolution mechanism is a special procedure in income tax law to address the tax disputes in the context of international transactions, especially the transfer pricing disputes, and certain specified domestic transactions. One of the recent legal disputes, which has been engaging the attention of the stakeholders of international transactions time and again, relates to the question whether the draft order or the final order passed under section 144C of the Indian Income Tax Act is governed by the general limitational proscriptions prescribed in section 153 thereof that. The recent single-judge decision of the Madras High Court in the Roca Bathroom case has intensified this polemic. The object of this article is to examine the interplay of section 153 vis-à-vis section 144C and review the judicial pronouncements on the relevant interpretive question in international tax disputes.

Keywords

Dispute resolution mechanism; International tax disputes; Dispute resolution panel; General rule of limitation; Income Tax Act, 1961.

.