JUDGMENT :

K.R.Shriram, J.

1. Writ Petition No.1784 of 2022 and Writ Petition No.1791 of 2022 pertain to Assessment Years 2010-11 and 2009-10, respectively. The facts are identical and therefore, we decided to dispose both the matters together by this common order. With the consent of the Parties, the Petitions are taken up for hearing at this stage itself. Rule.

Rule made returnable forthwith.

2. Petitioner filed its return of income for the respective years and the return of income was processed under Section 143(1) of the Income-tax Act, 1961 ("Act"). Subsequently, the case was selected for scrutiny and statutory notices were issued in both. As there were international transactions, a reference was made by the Assessing Officer ("AO") to the Transfer Pricing Officer ("TPO") under Subsection (2) of Section 92CA of the Act. The TPO passed an order under Section 92CA(3) of the Act making upward adjustment. On the basis of the said order of the TPO, the AO passed draft assessment order. The draft assessment order which contained additions was objected to by Petitioner before the Dispute Resolution Panel ("DRP") under Sub-section 5 of Section 144C of the Act. The DRP rejected the content