Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
HC held that uploading GST show cause notices solely in the 'Additional Notices and Orders' portal tab without clear navigation instructions constituted improper service. The taxpayer's unawareness of notices was justified as the portal's earlier scheme was confusing and vague regarding notice placement. The court found that absence of explicit directions on the main 'Notices and Orders' tab about checking additional tabs amounted to ineffective information dissemination. Given this procedural defect violated natural justice principles, the determination order under Section 73 was set aside. The petitioner was granted 30 days to respond to the notices, with the court emphasizing that proper service requires clear portal instructions for accessing statutory notices.
HC held that uploading GST show cause notices solely in the 'Additional Notices and Orders' portal tab without clear navigation instructions constituted improper service. The taxpayer's unawareness of notices was justified as the portal's earlier scheme was confusing and vague regarding notice placement. The court found that absence of explicit directions on the main 'Notices and Orders' tab about checking additional tabs amounted to ineffective information dissemination. Given this procedural defect violated natural justice principles, the determination order under Section 73 was set aside. The petitioner was granted 30 days to respond to the notices, with the court emphasizing that proper service requires clear portal instructions for accessing statutory notices.
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