GST authorities must use effective alternative service when portal notices go unanswered before passing an adverse order.

The petitioner challenged an assessment order dated 17 March 2026 under the Tamil Nadu Goods and Services Tax Act for 2020–21.

It contended that the show-cause notice and hearing notice had only been uploaded to the GST Portal, that it had not received physical copies, and that it had no opportunity to respond or be heard.

The petitioner offered to deposit 25% of the disputed tax and sought to have the assessment set aside and the matter reconsidered.

The respondent did not oppose remand on that condition.

Whether passing the assessment order after portal-only service, without an effective opportunity to respond and be heard, violated the principles of natural justice.

Whether the assessment order should be set aside and the matter remanded subject to the petitioner depositing 25% of the disputed tax.

The Court applied the principles of natural justice, including the requirement to afford a meaningful opportunity to respond and a personal hearing before making an adverse determination.

It also considered 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 identifies the Tamil Nadu Goods and Services Tax Act as the governing statute but cites no specific provision or precedent.

The Court accepted the petitioner’s account that the notices had been uploaded to the GST Portal without physical service and noted that the petitioner had not responded.

In those circumstances, it considered repeated portal uploads insufficient where alternative modes of service were available.

Because the resulting order was made without a personal hearing, the petitioner had not been afforded an adequate opportunity to establish its case; the Court therefore found a violation of natural justice and considered reconsideration on the merits appropriate.

The petitioner’s offer to deposit 25% of the disputed tax, accepted as a condition for remand, shaped the relief granted.

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

Upon receiving the reply, the respondent must give 14 clear days’ notice fixing a personal hearing and then decide the matter on the merits and in accordance with law.

Upon proof of the 25% payment, the petitioner’s bank account is to be defrozen forthwith.

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