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Improper Electronic Service of Notices: court held portal upload insufficient, allowing vires challenge and stay on recovery and attachment.

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....Validity of notifications issued under the impugned scheme was challenged on grounds that portal uploading under 'Additional Notices and Orders' did not constitute proper service and that non-compliance with statutory procedural requirements vitally affected the order's validity; the writ was entertained on those vires and natural justice grounds, and an interim restraint was granted on recovery while the attachment imposed by tax authorities is ordered lifted pending disposal of the petition.....

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Improper Electronic Service of Notices: court held portal upload insufficient, allowing vires challenge and stay on recovery and attachment.