JUDGMENT :

J.B.PARDIWALA, J.

1. By this writ application under Article 226 of the Constitution of India, the writ applicant has prayed for the following reliefs:

“(a) quash and set aside the impugned reference by Respondent No.1 to Respondent No.2 and the notice dated 20.12.2019 at Annexure ‘A’ to this petition.

(b) pending the admission, hearing and final disposal of this petition, to stay implementation and operation of the impugned notice dated 20.12.2019 at Annexure ‘A’ to this petition and stay the assessment proceedings for AY 2017-18 undertaken by Respondent No.1;

(c) any other and further relief deemed just and proper be granted in the interest of justice;

(d) to provide for the cost of this petition”

2. The case put up by the writ applicant, in his writ application, may be summarized as under:

3. The writ applicant is a limited company. It seeks to challenge the reference made by the respondent No.1 to the respondent No.2 under Section 92CA (1) of the Income Tax Act (for short, “the Act”), in relation to the computation of Arm’s Length Price on the ground of being erroneous, illegal and contrary to law. The writ applicant further seeks to challenge the notice under Sections 92CA