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    Foreign asset disclosure in a substituted return can defeat penalty for an earlier omission when assessment accepts it.
    Comparability filters in TNMM require upfront R&D screening and broadly similar turnover scales for software services.
    Functional comparability in wholesale auto-component trading excludes retail and after-sales comparables, deleting transfer pricing adjustments
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      Uploading GST notices or orders solely in the Common Portal's...

      Valid GST service requires prescribed statutory modes; portal uploads alone cannot trigger limitation, subject to waiver by participation.

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      GSTJuly 25, 2026Case LawsHC
      Uploading GST notices or orders solely in the Common Portal's "View Additional Notices and Orders" tab was not authorised service because the notified portal functions and Rules did not prescribe that tab as a statutory mode of service. Such uploading could not commence the appeal limitation period, particularly where the interface did not prominently disclose communications. E-mail service required transmission of the notice or order itself to the registered e-mail address; an intimation alone was insufficient. Ex parte proceedings based solely on invalid portal service were restored for reply and hearing, while affected appeals could be considered on merits. However, an assessee that replied to and contested a show-cause notice could not later challenge the resulting order solely for defective portal service.

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      ActsIncome Tax