Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
Mechanical approval under search assessment law vitiates assessments when sanction lacks application of mind; retrospective curative provision cannot ...
The HC held that electronic communication of the impugned order (email) satisfied service requirements under Section 169 CGST and that delay in uploading Form DRC-07 or portal posting did not render the order time-barred. The court found prima facie service by email sufficient despite multiple noticees and considerable ITC allegations. The impugned order was declared appealable; the Petitioner was permitted to file statutory appeals under Section 107 CGST by 30 September 2025 with the requisite pre-deposit. If filed within that period, the appeals shall not be dismissed on limitation grounds and shall be adjudicated on merits. Petition disposed.
The HC held that electronic communication of the impugned order (email) satisfied service requirements under Section 169 CGST and that delay in uploading Form DRC-07 or portal posting did not render the order time-barred. The court found prima facie service by email sufficient despite multiple noticees and considerable ITC allegations. The impugned order was declared appealable; the Petitioner was permitted to file statutory appeals under Section 107 CGST by 30 September 2025 with the requisite pre-deposit. If filed within that period, the appeals shall not be dismissed on limitation grounds and shall be adjudicated on merits. Petition disposed.
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