Section 379 — DRC | ITA 2025

Section 379 — - DISPUTE RESOLUTION COMMITTEE

Section 379 is the substantive equivalent of 1961 s. 245MA -- the DISPUTE RESOLUTION COMMITTEE (DRC) framework introduced FA 2021 as an ALTERNATIVE DISPUTE RESOLUTION mechanism for SMALL-TAXPAYER cases. The provision provides simplified faceless dispute resolution for: (a) eligible assessees with returned income <= INR 50 LAKH AND aggregate variation in assessment <= INR 10 LAKH; (b) settlement-style resolution with concessional tax / penalty / interest. Critical for small-taxpayer compliance burden reduction post-FA 2021 abolition of Settlement Commission. DRC operates within faceless framework.

Statutory text — Income-tax Act, 2025

Marginal note -- Dispute Resolution Committee

(1) The Central Government shall constitute, one or more Dispute Resolution Committees, as per the rules made under this Act, for dispute resolution in the case of such persons or class of persons, as specified by the Board, who opt for dispute resolution under this Chapter in respect of dispute arising from any vari- ation in the specified order in his case and who fulfils the specified conditions, as may be prescribed.

(2) The Dispute Resolution Committee, subject to the conditions as may be pre- scribed, may make modifications to the variations in specified order or reduce or 80 [waive any penalty imposed or imposable] under this Act, or grant immunity from prosecution for any offence punishable under this Act, in case of a person whose dispute is resolved under this Chapter.

(3) Irrespective of anything contained in section 275, upon receipt of the order of the Dispute Resolution Committee under this section, the Assessing Officer shall,—

(a) in a case where the specified order is a draft of the proposed order of assessment under section 275(1), pass an order of assessment, reassess- ment or recomputation; or

(b) in any other case, modify the order of assessment, reassessment or rec- omputation, in conformity with the directions contained in the order of the Dispute Resolution Committee within one month from the end of the month in which such order is received.

(4) For the purposes of this section, “specified order” means such order, including draft order, as specified by the Board, and—

(i) the aggregate sum of variations proposed or made in such order does not exceed ten lakh rupees;

(ii) such order is not based on search initiated under section 247 or requi- sition under section 248 in the case of assessee or any other person or survey under section 253 or information received under an agreement referred to in section 159(1) or (2);

(iii) where the assessee has filed a return for the tax year relevant to such order, total income as per such return does not exceed fifty lakh rupees. 2.—Advance rulings Interpretation.

Corresponding provision — 1961 regime

INCOME-TAX ACT, 2025	INCOME-TAX ACT, 1961
INCOME-TAX ACT, 2025 -- s. 379	INCOME-TAX ACT, 1961 -- s. 245MA [FA 2021]
Sub-s. (1) -- DRC framework	1961 s. 245MA(1)
Eligible assessee criteria	1961 s. 245MA(2)
DRC composition / procedure	1961 s. 245MA(3)/(4)
Concessional outcome (penalty / immunity)	1961 s. 245MA(5)
DRC order binding	1961 s. 245MA(6)

STATUTORY ARCHITECTURE

ELIGIBILITY: (I) Returned income <= INR 50 LAKH; AND (II) Aggregate VARIATION proposed in assessment <= INR 10 LAKH. Threshold-based small-taxpayer focus. DRC FUNCTIONS: (a) Provides ALTERNATIVE to traditional appellate route (CIT(A) / ITAT); (b) FACELESS framework via NFAC integration; (c) Simplified dispute resolution -- without prolonged litigation; (d) CONCESSIONAL outcomes: typically waiver / reduction of penalty / interest; partial immunity from prosecution. PROCEDURE: (I) Assessee files application during pending assessment; (II) DRC reviews; assesses suitability; (III) Provides settlement opportunity; (IV) Issues binding order. DRC COMPOSITION: typically PCIT/CIT level + outside member; faceless operations. POST-SETTLEMENT-COMMISSION: FA 2021 abolished Settlement Commission (1961 s. 245C); DRC partly fills this gap for smaller taxpayers.

PRACTITIONER NOTES

(i) ELIGIBILITY THRESHOLDS -- INR 50L returned + INR 10L variation; verify before applying. (ii) BENEFITS -- penalty / interest waiver; quicker resolution than litigation. (iii) DRAWBACKS -- DRC order binding; substantive grounds may be lost. (iv) APPLICATION TIMING -- during pending assessment; specific window. (v) FORM AND PROCESS -- e-filing / NFAC integration.

CROSS-REFERENCES

Section 357 -- CIT(A) appeals (alternative).
Section 362 -- ITAT appeals.
Section 380 -- DRC interpretation.

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