GST officers must explore alternative Section 169 service modes when portal notices receive no response.

The petitioner challenged two orders dated 20 April 2026, issued under Section 74 of the CGST/TNGST Acts, 2017, for financial years 2023–24 and 2022–23.

The petitioner stated that notices had been uploaded to the GST portal but were not seen, and that no personal hearing was provided before the orders were passed.

It also submitted that the disputed tax had been paid.

The respondent accepted that no personal hearing had been afforded and agreed to remittal.

1. Whether the assessment orders should be set aside where the notices were uploaded to the GST portal but no personal hearing was provided before the orders were passed

2. Whether, when a taxpayer does not respond to portal notices, the officer should explore other modes of service available under Section 169(1) of the GST Act

Section 169(1) of the GST Act recognises prescribed modes of serving notices and orders; portal service is a valid mode, but the Court held that where a taxpayer does not respond to notices sent through one mode, the officer should explore other available modes, preferably registered post with acknowledgment due (RPAD), to make service effective.

The Court also applied the requirement of a fair opportunity of personal hearing before final orders are made in the circumstances of this case.

The proceedings arose under Section 74 of the CGST/TNGST Acts, 2017.

Although uploading notices to the GST portal constituted valid service, the petitioner’s non-response should have prompted the officer to consider other modes under Section 169(1), rather than proceed on the basis of portal service alone.

The respondent also acknowledged that no personal hearing had been given.

In these circumstances, and noting the petitioner’s submission that the disputed tax had been paid, the Court found it appropriate to set aside the orders and remit the matters for fresh consideration.

The petitioner was directed to file its reply or objections, with supporting documents, within three weeks of receiving the order.

Upon receipt, the respondent must issue 14 days’ clear notice fixing a personal hearing and then pass appropriate orders on the merits and in accordance with law.

The petitions were disposed of without costs, and the connected miscellaneous petitions were closed.