Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
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Portal-only GST service may be inadequate where it does not provide effective notice of the complete show cause notice or reasoned order and thereby denies a meaningful opportunity to respond. Section 169 permits Common Portal availability as a mode of service, but Rule 142 distinguishes FORM GST DRC-01 and DRC-07 electronic summaries from the underlying notice or order. Section 75 requires a hearing where an adverse decision is contemplated and reasons in the adjudication order. Retrospective expansion of Common Portal functions does not by itself cure deficient communication. For appellate limitation, proof of upload or dispatch may not establish effective communication where accessibility, actual or constructive knowledge, or retrieval of the complete communication remains unproven.
Portal-only GST service may be inadequate where it does not provide effective notice of the complete show cause notice or reasoned order and thereby denies a meaningful opportunity to respond. Section 169 permits Common Portal availability as a mode of service, but Rule 142 distinguishes FORM GST DRC-01 and DRC-07 electronic summaries from the underlying notice or order. Section 75 requires a hearing where an adverse decision is contemplated and reasons in the adjudication order. Retrospective expansion of Common Portal functions does not by itself cure deficient communication. For appellate limitation, proof of upload or dispatch may not establish effective communication where accessibility, actual or constructive knowledge, or retrieval of the complete communication remains unproven.
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