Dispute Resolution Panel | Chartered Accountants for the UK

The Dispute Resolution Panel,before the order is final.

When a transfer pricing adjustment is proposed, Indian subsidiaries of UK groups get a draft order first. Within 30 days they can object to the Dispute Resolution Panel, a panel of three senior Commissioners, and the officer must follow its directions. We prepare the objections and argue the case.

Objections in 30 daysFees agreed in writingHearings handled

How the DRP works.

Draft

Draft order

The officer proposes the adjustment in a draft order.

Choose

DRP or accept

Object to the DRP within 30 days, or accept and appeal to the CIT(A).

Hear

Panel hearing

Written objections, evidence and hearings.

Direct

Directions

Within nine months from the end of the month the draft was sent.

Finalise

Final order

The officer passes the final order following the directions.

Old and new section numbers

From 1 April 2026 the Income-tax Act, 2025 has renumbered the transfer pricing provisions. Cases for years before tax year 2026-27 still run under the Income-tax Act, 1961, so this page uses the familiar section numbers. We apply whichever Act covers your year.

DRP or CIT(A)?

Point	DRP route	CIT(A) route
Demand	Not raised until the final order	Raised with the assessment order
Time to a decision	Fixed: nine months	No fixed time
Next appeal	Straight to the ITAT	To the ITAT after CIT(A)
Who can use it	Foreign companies and cases with a TP adjustment	Everyone

Writing strong objections.

One ground per issueComparables, filters, method and adjustments argued separately.
Fresh evidenceUpdated data, agreements and proof of services.
Alternative pleasFallback positions such as working capital adjustments.
Earlier yearsTribunal rulings in your own earlier cases.

Why UK companies choose us in India.

We speak UK and India

We work with your UK finance team, lawyers and auditors, and translate Indian requirements into plain English.

Reviewed before filing

Every filing and certificate is checked by a second Chartered Accountant before it goes in.

Fees agreed in writing

A written scope, timetable and fee before work starts.

A compliance calendar

One calendar of every MCA, RBI, GST and income-tax deadline for your Indian entity.

One team end to end

Set-up, accounts, payroll, tax, audit and RBI filings handled together.

Secure and fully online

Encrypted document sharing and digital signatures. Directors never need to travel.

DRP representation for UK groups.

We support UK groups headquartered anywhere in the UK with transfer pricing for their Indian subsidiaries and branches, working with their UK tax teams online.

London

City of LondonCanary WharfHarrowWembleySouthallHounslowIlfordEast HamCroydonEdgware

South East

ReadingSloughMilton KeynesOxfordWatfordLutonCrawleyGuildford

Midlands

BirminghamLeicesterCoventryNottinghamWolverhamptonDerbyNorthampton

North of England

ManchesterLeedsBradfordSheffieldLiverpoolNewcastlePreston

East and South West

CambridgePeterboroughBristolSwindonSouthamptonBath

Scotland, Wales, NI

EdinburghGlasgowAberdeenDundeeCardiffSwanseaBelfast

Transfer pricing DRP FAQs.

Foreign companies, and any company whose draft order includes a TP adjustment.

30 days from receiving the draft order.

Yes on the officer. You can still appeal to the ITAT.

No demand arises until the final order is passed.

Received a draft order?

The 30-day clock is running. Send it to us and we will prepare the objections.

Discuss a draft order +91 9819 000 511

This page is general guidance based on the Income-tax Act, 2025 and the rules and return forms as they stand. It is not legal or financial advice for your situation. Forms, eligibility and due dates can change each year, so please check with us before filing.