2025 (1) TMI 973

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....: Mr Manuj Sabharwal with Mr Drona Negi and Mr Devvrat Tiwari, Advocates For the Respondents: Mr Sunil Agarwal, SSC with Mr Shivansh B Pandiya, Mr Viplav Acharya, Ms Priya Sarkar and Mr Utkarsh Tiwari, Advocates ORDER 1. The petitioner has filed the present petition, inter alia, praying as under: "a. Issue a writ in the nature of certiorari or mandamus or any other appropriate writ(s), order(....

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....nsaction. 3. The TPO passed an order dated 30.10.2023 under Section 92CA(3) of the Act directing an upward adjustment of Rs.8,12,99,944/- on account of the determination of ALP in respect of the international transaction. 4. In the meanwhile, the Central Processing Centre (CPC) issued an intimation under Section 143(1) of the Act, which according to the petitioner was erroneous. Therefore, the p....

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....oner's request was not considered and the DRP passed an order dated 20.09.2024 under Section 144C(5) of the Act with the direction that the petitioner's rectification application which was pending, be decided. 8. Thereafter, the petitioner filed an application for rectification of the order dated 20.09.2024 passed by the DRP on the ground that it had entered into the APA and its modified return w....