In the result, the appeal is allowed for statistical purposes
Bench: Shri R.S. Syal & Shri S.S.Viswanethra Raviआयकर अपील सं. / Ita Nos.338/Pun/2021 & 236/Pun/2022 "नधा"रण वष" / Assessment Years : 2016-17 & 2017-18
Transfer Pricing Officer or any other authority; and records relating to the draft order. This shows that the direction is issued by the DRP after giving full opportunity of hearing to the assessee, which is further ostensible from sub-section (11), unequivocally providing to that extent, by stating that no direction under sub-section (5) shall be issued unless