Section 9 and 144C of the Income Tax Act, 1961 — Non Resident — DRP had failed to exercise its jurisdiction and had rendered the entire process of Dispute resolution under the scheme of Act farcical and a perusal of the objections recorded by the Panel under section 144C(5) showed that the main or the basis contention raised by the assessee with respect to the non taxability of its incine under DTAA had not been considered or discussed and adjudicated upon — Matter remanded to DRP as DRP confirmed draft assessment order without considering material on record — PDR Solitions FZC vs. DRP [2019] 418 ITR 277(Delhi)