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HC held that limitation under Section 107 begins to run only from the date the order or decision is communicated to the assessee, not from mere uploading of the impugned order on the GSTN portal; statutory obligation to "communicate" is distinct from "serve" and requires actual imparting or transmission to the recipient, which unilateral portal upload does not satisfy absent proof of communication or receipt. The court clarified that there is no statutory duty on the assessee to access the portal and that section 169's service provisions are separate. The writ petition by the appellant was disposed of accordingly.
HC held that limitation under Section 107 begins to run only from the date the order or decision is communicated to the assessee, not from mere uploading of the impugned order on the GSTN portal; statutory obligation to "communicate" is distinct from "serve" and requires actual imparting or transmission to the recipient, which unilateral portal upload does not satisfy absent proof of communication or receipt. The court clarified that there is no statutory duty on the assessee to access the portal and that section 169's service provisions are separate. The writ petition by the appellant was disposed of accordingly.
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