Transfer Pricing — DRP the fast-track forum after a TP draft order.
End-to-end representation before the Dispute Resolution Panel under Section 144C — drafting of objections, paper books, oral hearings, and coordination for the final assessment that follows DRP directions.
The Dispute Resolution Panel is a three-member collegium of senior tax officers that hears objections against draft assessment orders involving transfer pricing adjustments or foreign company assessments. It was introduced under Section 144C to provide a faster route than the regular CIT(A) cycle and to dispose of TP disputes within nine months.
Choosing DRP over CIT(A) is a strategic call. DRP is faster and binding on the Assessing Officer, but its directions cannot be challenged before CIT(A) — the next forum is directly ITAT. The election has to be made within 30 days of the draft order, and once made it cannot be reversed.
We help eligible taxpayers evaluate the DRP route, draft tight, focused objections within the 30-day window, prepare panel-ready paper books, and represent the case in oral hearings. Post-DRP, we coordinate with the AO for the final assessment order and prepare the ITAT appeal where required.
Our Transfer Pricing — DRP Services
DRP vs CIT(A) Strategy
Decision on DRP versus CIT(A) route based on facts and quantum.
Objection Drafting
Drafting of detailed objections on every TP and corporate tax issue.
Paper Book Preparation
Compilation of facts, TP study, comparables, and judicial precedents.
DRP Hearing Representation
Oral representation before the three-member DRP.
Additional Evidence
Additional evidence submission with proper justification.
DRP Directions Review
Detailed review of DRP directions and impact analysis.
Final AO Order
Coordination with the AO on the final assessment per DRP directions.
Post-DRP ITAT Appeal
ITAT appeal drafting and filing where DRP order is unfavourable.
Our Approach
Draft Order Review
Detailed review of draft assessment order and TPO order.
Route Selection
DRP versus CIT(A) route decision within 30 days.
Drafting & Filing
Objections drafted, paper book compiled, and filing within timeline.
Hearing
Oral submissions made in DRP hearings.
Implementation
Final AO order tracked; ITAT appeal filed if needed.
Why It Matters
Frequently Asked Questions
A three-member panel of senior tax officers hearing objections to draft assessment orders.
Eligible assessees with TP adjustments or those classified as foreign companies.
Yes, DRP directions are binding on the Assessing Officer for the final order.
No, the next forum after DRP is directly the ITAT.
30 days from the date of receipt of the draft assessment order.
Got a TP Draft Order?
Use the DRP window wisely — 30-day filing, focused objection drafting, and panel-ready advocacy by Chartered Accountants with hands-on DRP experience.
File My DRP Objection or call +91 9819 000 511