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 Calcutta HC appointed a sole arbitrator to decide the long-pending lease-renewal dispute between G.E.T. Properties and DGGI, observing that the arbitration clause survived the expired lease.