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Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
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For GST adjudication orders under Section 73, issuance within the limitation period is distinct from service. The provision requires the proper officer to complete and digitally authenticate the adjudicatory order within time, while Section 169 governs communication through prescribed service modes. Uploading a summary in Form GST DRC-07 under Rule 142(5) does not make the upload date the date of issuance or impose a requirement that service be completed within the issuance limitation period. Accordingly, an order digitally signed within the extended period remains valid even if uploaded on the common portal the following day; the later upload affects service and enforceability, not validity.
For GST adjudication orders under Section 73, issuance within the limitation period is distinct from service. The provision requires the proper officer to complete and digitally authenticate the adjudicatory order within time, while Section 169 governs communication through prescribed service modes. Uploading a summary in Form GST DRC-07 under Rule 142(5) does not make the upload date the date of issuance or impose a requirement that service be completed within the issuance limitation period. Accordingly, an order digitally signed within the extended period remains valid even if uploaded on the common portal the following day; the later upload affects service and enforceability, not validity.
Note: It is a system-generated summary and is for quick reference only.