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2025 (1) TMI 1423

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..... ies as well as the Karnataka Authorities are seeking to tax the Petitioner on the very same transaction. The Karnataka Authorities have in fact brought the entire amount of Rs. 6092 Crores to tax. The Maharashtra Authorities are now seeking to bring a part of that consideration (i.e. part of Rs. 6092 Crores) to tax within the state. Further, the Karnataka High Court has already granted a stay on the show cause notice issued by the Karnataka Authorities bringing the entire amount of Rs. 6092 Crores to tax. There is no merit in the Preliminary Objection and the above Writ Petition is certainly entertained. The preliminary objection is therefore rejected. As far as Interim reliefs are concerned, considering that important legal issues are inv .....

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..... ts adjudication. In case the Petitioner is correct in its legal stand, then the show cause notice will be dropped. The Petitioner, therefore, ought not to burden the record of this Court. He submitted that the present Writ Petition is nothing but a chance litigation and deserves to be dismissed with heavy costs. 3. We have heard Mr. Sridharan, learned Senior Counsel appearing on behalf of the Petitioner as well as the learned Advocate appearing on behalf of the Respondents. The principle ground of challenge to the show cause notice is the fact that the amount that is sought to be taxed by the Respondents herein is the reward amount received by the Petitioner from its Group Company in Honkong in the year 2018-19 and 2019-20. The reward rece .....

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..... e Court (under Article 32 of the Constitution) was negated by the Hon'ble Supreme Court. He therefore submitted that in the present case, there is no merit in the preliminary objection and the same be rejected. 5. As far as the preliminary objection regards the maintainability of the Writ Petition is concerned, we do not find any merit. Prima facie, after going through the Petition, we find that the Maharashtra Authorities as well as the Karnataka Authorities are seeking to tax the Petitioner on the very same transaction. The Karnataka Authorities have in fact brought the entire amount of Rs. 6092 Crores to tax. The Maharashtra Authorities are now seeking to bring a part of that consideration (i.e. part of Rs. 6092 Crores) to tax within th .....

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