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alternative remedy. This is for the reason that in terms of Section 144C (5) read with Section 144 C (8) , the DRP has no jurisdiction

under section 92CA(1) or suo moto under section 92CA(2A) and/or (2B). Sub-section (1) provides that if the AO considers it necessary ... total income of the assessee under section 92C(4) in conformity therewith, the provisions of section 144C relating to a reference to the Dispute Resolution