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Challenge to the validity of the SCN on the ground that it was issued by an incompetent officer was rejected because, though the portal reflected the Superintendent, the SCN was actually signed by the competent Joint Director; consequently, the SCN was not invalidated. Objection to appellate forum/jurisdiction was rejected as the correct appellate authority was the Commissioner (Appeals), and the impugned DRC-07 was only a portal summary uploaded by the jurisdictional commissionerate based on the highest tax-demand principle in multi-notice adjudications; consequently, the petitioner was relegated to the statutory appeal, with a direction that an appeal filed by 31-01-2026 with pre-deposit shall not be dismissed as time-barred and must be decided on merits. - HC
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