2025 (7) TMI 1593

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....For the Appellant : Mr. Mukesh Butani, Mr. Shankey Agrawal, Mr. Siddharth Agrawal and Mr. Saurabh Nandy, Advocates. For the Respondent : Mr. Gaurav Gupta, Sr. Standing Counsel with Mr. Shivendra Singh and Mr. Yojit Pareek, Jr. Standing Counsels and Mr. Surya Jindal, Advocate for Revenue. ORDER 1. The petitioner has filed the present petition, inter alia, praying as under: "a) All....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....passed under Section 144C(1) of the Income Tax Act, 1961 is not in conformity with the order passed by the Transfer Pricing Officer [TPO] in regard to the determination of the Arm's Length Price [ALP] of the International transaction. He submits that the Assessing Officer does not have any jurisdiction to determine the ALP and must necessarily pass orders in conformity with the decision of the TPO....