The Court reaffirmed that both provisions operate independently, even after the 2022 amendments, and cannot be treated as mutually exclusive in a manner that restricts the Revenue’s statutory powers.

The Tribunal observed that revenue has compared the figures reflected in the ST-3 returns and figures reflected in Form 26AS statement and raised the demand without further examining the reasons for the difference in the two statements.

The court observed that CCI’s orders are in rem, binding across the industry, and therefore parties with a direct interest must be heard under Regulation 26 of the CCI (General Regulations), 2024