Permanent establishment tests: independent subsidiary premises and principal-to-principal dealings did not create Indian taxability for offshore suppl...
Valuation Officer estimates govern property-value additions once statutory valuation is invoked, requiring fresh consideration of objections and compa...
Waiver of written show-cause notice may prevent a later procedural challenge after participation in customs adjudication, preserving statutory appella...
Retrospective invalidity of ocean-freight IGST supports refunds despite non-party status and prior credit utilisation, subject to authorised appeal gr...
Additional evidence in departmental appeals may include show-cause-notice material without introducing a new case where it merely corroborates existin...
Reasoned rectification orders require consideration of expenditure disclosed in income-tax returns, preventing revision based on incomplete income com...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
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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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