Dismissing the petition the Court held that merely because the order of the Dispute Resolution Panel may be binding on the Assessing Officer, against whose order, the appeal can be filed only before the Tribunal, a shortcut cannot be provided to the assessee to invoke the writ jurisdiction, which itself has three tiers of remedies ; before the High Court, two tiers, viz., the single judge dealing with the writ petition and the intra-court writ appeal before the Division Bench and then if the matter is taken up to the Supreme Court by way of a special leave petition under article 136 of the Constitution of India. If the matter is dragged through these three tiers, it would be impossible for the orders of the Dispute Resolution Panel to be executed by the Assessing Officer and the Tribunal to apply its mind to the factual aspects of the matter for a long period. Even questions of law which are coupled or mixed with the findings of fact can be raised and argued before the concerned authorities below, including the Transfer Pricing Officer and before the Tribunal. Such a digression from the normal channel of the remedies provided in the Act in Chapter X, need not be cut short by allowing the assessee to invoke the writ jurisdiction in such cases. The streamlined procedure, provided under the Act should not normally be allowed to be breached in cases where a deeper analysis of facts has to be done by the authorities under the Act up to the Tribunal and a factual exercise has to be undertaken by them with regard to comparables, transfer pricing adjustments and methods for making transfer pricing adjustments as prescribed in rule 10B of the Income-tax Rules, 1962 , and section 92C of the Income-tax Act, 1961 . Prematurely pronouncing on these issues, definitely curtails the discretion of the assessing authorities in this regard and it is a self defeating exercise, which the High Court in its writ jurisdiction would be reluctant to undertake.( AY.2012-13)