GST authorities must ensure effective notice service before passing ex parte assessment orders.

The petitioner challenged an assessment order dated 24 December 2025.

It submitted that the show-cause notice and personal-hearing notice had only been uploaded to the GST Portal, that it had received no physical copies, and that it therefore had no opportunity to respond or be heard.

The petitioner offered to deposit 25% of the disputed tax and sought to file objections and receive a personal hearing.

The respondent did not oppose remand on that condition.

1. Whether passing the assessment order after uploading notices to the GST Portal, without an effective opportunity for the petitioner to respond and be heard, violated the principles of natural justice

2. Whether the assessment order should be set aside and the matter remitted for reconsideration subject to a deposit of 25% of the disputed tax

The Court applied the principles of natural justice, including the requirement that a person affected by an assessment receive a meaningful opportunity to respond and be heard.

It also noted that the statute provides alternative modes of service and held that, where no response is received, the authority should adopt an effective mode of service rather than repeatedly relying on uploads to the common portal.

The judgment does not identify a specific statutory provision or precedent.

The Court accepted that the notices had been uploaded to the GST Portal but that the petitioner claimed not to have known of them and had not received physical copies.

Because the respondent received no response, and alternative statutory modes of service were available, the Court considered it incumbent on the respondent to use an effective mode of service.

In the circumstances, the petitioner had not received a proper opportunity to establish its case, including through a personal hearing; the order therefore could not stand.

The petitioner must file its reply and supporting documents within two weeks thereafter.

The respondent must then consider the reply, give 14 days’ clear notice fixing a personal hearing, and pass fresh orders on the merits and in accordance with law.

The writ petition was disposed of without costs, and the connected miscellaneous petition was closed.