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Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Uploading a GST show-cause notice or adjudication order only in the 'View Additional Notices and Orders' tab of the Common Portal is not sufficient service unless the taxpayer acknowledges receipt or responds. The notes state that the retrospective amendment on Common Portal functions does not change this position because the GST Rules do not prescribe portal upload as a mode of service for such notices or orders. If no reply was filed and an ex parte order followed, proceedings must be restored to the notice stage. If an order followed a contested proceeding but was only uploaded on the portal, the limitation period for appeal does not commence.
Uploading a GST show-cause notice or adjudication order only in the 'View Additional Notices and Orders' tab of the Common Portal is not sufficient service unless the taxpayer acknowledges receipt or responds. The notes state that the retrospective amendment on Common Portal functions does not change this position because the GST Rules do not prescribe portal upload as a mode of service for such notices or orders. If no reply was filed and an ex parte order followed, proceedings must be restored to the notice stage. If an order followed a contested proceeding but was only uploaded on the portal, the limitation period for appeal does not commence.
Note: It is a system-generated summary and is for quick reference only.