GST officers must explore alternative statutory service modes when portal notices go unanswered.

The petitioner challenged an assessment order dated 24 November 2025, arguing that it had not seen notices uploaded to the GST portal and had consequently failed to respond.

The respondent acknowledged that no personal hearing had been provided before the order was passed.

The petitioner offered to pay 25% of the disputed tax amount, and the respondent consented to remand subject to that payment.

The Court noted that the show-cause notice had been uploaded on the portal, but that the petitioner claimed it was unaware of the notice and had not received the original.

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

Whether the assessment order should be set aside and the matter remanded where no personal hearing was given, subject to payment of 25% of the disputed tax

Section 169(1) of the GST Act recognises multiple valid modes for serving notices and orders.

Although service by uploading a notice to the GST portal is sufficient, where the taxpayer does not respond, the officer should consider other prescribed modes—preferably registered post with acknowledgment due (RPAD)—to make service effective rather than merely formal.

The Court also proceeded on the basis that the petitioner should receive a personal hearing before fresh assessment orders were made.

The Court accepted that portal upload constituted valid service, but considered that the petitioner’s non-response should have prompted the officer to explore other available service methods.

In the Court’s view, reliance on portal upload alone, followed by an ex parte assessment without a personal hearing, reflected insufficient efforts to effect service and risked unnecessary further litigation.

In light of the respondent’s concession and the petitioner’s undertaking to pay 25% of the disputed tax, the Court found remand appropriate.

The petitioner was directed to file its reply and supporting documents within three weeks after payment.

The respondent was then to provide 14 clear days’ 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.