The Court thus struck a balance between statutory discipline and equitable fairness, ensuring that small taxpayers are not denied appellate remedies solely due to portal-based deemed service.

Assessee had obtained the certificates from the embassies, even though some were furnished after adjudication. Therefore the tribunal’s decision to remand is proper.

The High Court at Madras took note of the fact that the transactions were during the first year of the TNGST regime and allowed the petition with conditions.