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    <description>Limitation for filing an appeal before the Commissioner (Appeals) was examined by reference to the date of service of the adjudication order. Postal tracking records showed delivery to the appellant on 11 January 2023, so the asserted later receipt date was not accepted. The cited precedent was treated as distinguishable because documentary proof of delivery existed in this matter. On that basis, the appeal was described as time-barred, with the finding against the assessee.</description>
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      <description>Limitation for filing an appeal before the Commissioner (Appeals) was examined by reference to the date of service of the adjudication order. Postal tracking records showed delivery to the appellant on 11 January 2023, so the asserted later receipt date was not accepted. The cited precedent was treated as distinguishable because documentary proof of delivery existed in this matter. On that basis, the appeal was described as time-barred, with the finding against the assessee.</description>
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