2022 (5) TMI 1014

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..... l gains tax at the rate of 20% instead of 10% - DRP has examined the first ground viz. the arm s length and has issued certain directions which has resulted in the Assessment orders that are impugned in the respective appeals as aforesaid, the DRP has not examined the second ground on the question of its jurisdiction - HELD THAT:- This Court, in the peculiar circumstances of the case, and the fac .....

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..... onding directions are produced as annexures in the respective writ petitions. 2. Sri. Percy Pardiwalla, the learned Senior Counsel, submits that during the pendency of these writ petitions, the Assessment Orders have been passed incorporating the directions issued by the DRP on 20.07.2018 and these Assessment Orders have been called in question by the petitioners in their respective appeals und .....

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..... e only question that could be gone into are as regards the incorporation of the DRP s directions on arm s length and because the DRP has not decided the question on rates, the same would be outside the consideration of the appellate Tribunal in the respective appeals. With necessary clarifications in this regard, the petitions could be disposed of lest the petitioners be excluded from the appellat .....

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