Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
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High Court noted petitioner challenged a refund rejection and an administrative circular but bypassed the alternative remedy of appeal under the CGST regime; invoking principles of natural justice did not prevent relegation to the statutory appellate forum. The court disposed the writ, permitting the petitioner to prefer an appeal within two weeks accompanied by a delay-condonation application and directing the appellate authority to consider all factual and legal grounds previously pursued in writ jurisdiction. No observations were made on the merits of the refund claim or the circular's validity.
High Court noted petitioner challenged a refund rejection and an administrative circular but bypassed the alternative remedy of appeal under the CGST regime; invoking principles of natural justice did not prevent relegation to the statutory appellate forum. The court disposed the writ, permitting the petitioner to prefer an appeal within two weeks accompanied by a delay-condonation application and directing the appellate authority to consider all factual and legal grounds previously pursued in writ jurisdiction. No observations were made on the merits of the refund claim or the circular's validity.
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