Rectification order by DRP based on Rectification application by TPO is Not maintainable

Shapoorji Pallonji Bumi Armada Pvt Ltd Vs ACIT (ITAT Mumbai) We have noted that the Dispute Resolution Panel, having rejected the rectification application filed by the Transfer Pricing Officer and having held that there is no mistake apparent in the direction dated 3rd November 2020, have proceeded to rectify these DRP directions nevertheless. Undoubtedly, if the DRP was of the opinion that there are mistakes apparent in the directions issued by the DRP, they could have taken a suo motu cognizance of the same and initiated the proceedings by the issuance of show-cause notice, setting out clea...