Case Law Analysis
|Income Tax Appellate Tribunal
Section 254 IT Act | ITAT Lacks Jurisdiction to Direct DRP or TPO; Only AO Can Be Directed : ITAT Bangalore
ITAT Bangalore reaffirms judicial discipline in tax proceedings by holding that under Section 254 of the Income Tax Act, only the Assessing Officer (AO) can be directed to reconsider matters. Directions to the Dispute Resolution Panel (DRP) or Transfer Pricing Officer (TPO) are ultra vires, reinforcing the statutory hierarchy in transfer pricing disputes.