The Court rejected the State’s objection that an earlier writ petition challenging Section 16(4) barred the present claim, holding that Section 16(5) constitutes a fresh cause of action.

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.

Companies such as Maruti Suzuki, Hyundai, Nissan, and Volkswagen export significant volumes of compact cars and SUVs from India to Mexico.