Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
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An electronic GST penalty order was upheld despite not separately displaying a DIN because it carried a portal-verifiable RFN and had been served through statutory modes recognised under section 169, including the common portal, registered post and e-mail. The Court held that a challenge based only on the absence of the DIN label could not succeed where the communication was traceable and authentic, and relied on the CBIC circular dated 09.06.2025 clarifying that portal-generated communications with a verifiable RFN do not require a separate DIN. The writ petition was dismissed, with liberty to pursue the statutory appeal and exclusion of writ time for limitation purposes.
An electronic GST penalty order was upheld despite not separately displaying a DIN because it carried a portal-verifiable RFN and had been served through statutory modes recognised under section 169, including the common portal, registered post and e-mail. The Court held that a challenge based only on the absence of the DIN label could not succeed where the communication was traceable and authentic, and relied on the CBIC circular dated 09.06.2025 clarifying that portal-generated communications with a verifiable RFN do not require a separate DIN. The writ petition was dismissed, with liberty to pursue the statutory appeal and exclusion of writ time for limitation purposes.
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