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

The petitioner challenged the first respondent’s order dated 10 December 2025 under Section 73 of the Tamil Nadu Goods and Services Tax Act, 2017/Central Goods and Services Tax Act, 2017, including the summary in Form GST DRC-07 for FY 2021–22.

The petitioner said the notices were uploaded under “View Additional Notices and Orders” on the GST portal and were not brought to their attention; the petitioner consequently did not reply.

The assessment order was passed without a personal hearing.

The petitioner offered to pay 25% of the disputed tax, and the respondents consented to remand on that condition.

The Court noted that the show-cause notice had been uploaded to the portal and that no personal hearing had been given.

1. Whether the assessment order should be set aside and the matter remanded where notices were uploaded to the GST portal, the taxpayer did not respond, and no personal hearing was provided.

2. Whether remand should be conditional on payment of 25% of the disputed tax and accompanied by directions for a fresh hearing and release of the bank-account attachment.

Section 169(1) of the GST Act recognises multiple valid modes of service.

Although uploading a notice to the GST portal is a sufficient mode of service, where a taxpayer does not respond to repeated portal notices, the officer should consider other prescribed modes of service—preferably registered post with acknowledgment due—to make service effective.

The Court also proceeded on the admitted absence of a personal hearing before the impugned order was passed.

No precedent was cited.

The Court accepted that portal service was legally sufficient, but held that repeated non-response called for consideration of other service modes under Section 169(1), rather than reliance on portal uploads alone.

It regarded the absence of a personal hearing, which the respondents fairly admitted, as a further reason to permit the petitioner to present their case afresh.

Given the petitioner’s undertaking to pay 25% of the disputed tax and the respondents’ consent to remand on that condition, the Court set aside the order subject to payment and directed a fresh adjudication.

The petitioner must file a reply with supporting documents within three weeks of payment.

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

The bank attachment must be lifted, and the respondent must instruct the bank to release and defreeze the account immediately upon proof of payment.

No costs were ordered.