DRP Representation & Dispute Resolution Services
When a transfer pricing adjustment hits, you don’t always need to go down the long appeal route.
There’s a faster, more strategic option: the Dispute Resolution Panel (DRP).
At N D Savla & Associates, we help you navigate DRP proceedings with a clear objective — resolve disputes early, reduce tax exposure, and avoid prolonged litigation.
What this really means for you
The DRP is a fast-track dispute resolution mechanism under the Income Tax Act designed specifically for transfer pricing and international tax matters.
Instead of directly going through traditional appeals, you get an opportunity to challenge adjustments before the final assessment order is passed.
Here’s how it works in simple terms:
Tax officer proposes an adjustment in a Draft Assessment Order
You file objections before the DRP (within 30 days)
A panel of senior tax reviews your case
Directions are issued, which are binding on the Assessing Officer
This stage can significantly impact your final tax liability.
Why DRP matters
It shortens the litigation cycle compared to traditional appeals
You get your case reviewed by a panel of three Commissioners
It allows you to challenge adjustments before they become final
Strong representation here can avoid years of litigation
What this really means is:
If handled well, DRP can save both time and tax.
Where businesses usually go wrong
Filing generic or weak objections
Treating DRP as a formality instead of a strategic opportunity
Not aligning arguments with transfer pricing documentation
Missing timelines or incomplete submissions
Once directions are issued, reversing them later becomes harder.
Our Approach
We don’t just file objections. We build a case that can actually stand.
1. Draft Order Review
We analyze the adjustment and identify exactly where it can be challenged.
2. Strategy & Positioning
Clear, focused grounds of objection backed by facts and technical reasoning.
3. Detailed Submissions
Preparing strong written submissions with proper benchmarking and documentation support.
4. Representation Before DRP
Handling hearings, clarifications, and follow-ups with authorities.
5. Post-DRP Strategy
Guidance on next steps, including ITAT if required.
What Powers Does DRP Have?
The DRP has wide authority to:
Confirm the proposed adjustment
Reduce or delete additions
Enhance or modify variations
Call for further information or enquiry
Its directions are binding on the Assessing Officer, which makes this stage critical.
Who Should Consider DRP?
Companies facing transfer pricing adjustments
Foreign companies or entities with cross-border transactions
Businesses wanting faster resolution instead of long appeals
Cases involving high-value tax exposure
F.A.Q.
It is a dispute resolution mechanism that allows taxpayers to challenge transfer pricing adjustments before the final assessment order is passed.
Foreign companies and taxpayers where transfer pricing adjustments are proposed in a draft assessment order.
Objections must be filed within 30 days from receipt of the draft assessment order.
Yes. It is designed as a fast-track mechanism to resolve disputes more efficiently than traditional appellate routes.
Yes. The Assessing Officer must pass the final order based on DRP directions.
Yes. You can directly appeal to the Income Tax Appellate Tribunal (ITAT) if required.
We handle the entire DRP process, from drafting objections to representation, ensuring your case is presented clearly and strategically.
