Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
Writ interference despite an alternative statutory remedy is confined to cases of patent jurisdictional defect or manifest breach of natural justice. Complaints that the reply was inadequately considered, hearing notices were not served, a statement was coerced and later retracted, or cross-examination was denied were treated as issues of factual appraisal or merits for the appellate forum, so the writ was not entertained and the petitioner was left to the statutory appeal. The Court also accepted that the proper officer conducting Section 73 or 74 adjudication can impose consequential penalty under Section 122 in the same proceeding, without separate penalty proceedings, and rejected the competence challenge.
Writ interference despite an alternative statutory remedy is confined to cases of patent jurisdictional defect or manifest breach of natural justice. Complaints that the reply was inadequately considered, hearing notices were not served, a statement was coerced and later retracted, or cross-examination was denied were treated as issues of factual appraisal or merits for the appellate forum, so the writ was not entertained and the petitioner was left to the statutory appeal. The Court also accepted that the proper officer conducting Section 73 or 74 adjudication can impose consequential penalty under Section 122 in the same proceeding, without separate penalty proceedings, and rejected the competence challenge.
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