Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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The High Court dismissed the appeal, upholding the Single Judge's decision to relegate the appellant to the alternative remedy of replying to the show cause notices and adjudication by the statutory authority. The Department suspected availing of input tax credit on bogus invoices, prompting the issuance of an intimation u/r 86A to prevent irregular availment. Although there was a delay in issuing show cause notices, the appellant did not approach the court during that period. The court found no grounds for belated interference with the intimation under Article 226, as the appellant had the statutory recourse of adjudication after responding to the show cause notices.
The High Court dismissed the appeal, upholding the Single Judge's decision to relegate the appellant to the alternative remedy of replying to the show cause notices and adjudication by the statutory authority. The Department suspected availing of input tax credit on bogus invoices, prompting the issuance of an intimation u/r 86A to prevent irregular availment. Although there was a delay in issuing show cause notices, the appellant did not approach the court during that period. The court found no grounds for belated interference with the intimation under Article 226, as the appellant had the statutory recourse of adjudication after responding to the show cause notices.
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