Effective hearing in GST adjudication requires actual opportunity to respond; ineffective service through a former auditor invalidated ex parte procee...
Third-party search material requires special assessment route, rendering general reassessment notices without jurisdiction when it forms the proceedin...
Transfer-pricing adjustments must be confined to international associated-enterprise transactions, while functionally dissimilar comparables remain ex...
Insolvency moratorium bars income-tax revision proceedings against corporate debtors until the moratorium ends, preserving merits for later determinat...
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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