GST officers should use alternative Section 169 service modes when portal notices go unanswered.

The petitioner challenged an assessment order dated 19 December 2025 and consequential recovery proceedings, contending that notices had been uploaded only to the GST common portal and that it had not become aware of them.

The petitioner had not filed a reply, and the assessment was made without a personal hearing. The respondent accepted that no personal hearing had been given and agreed to remittal subject to the petitioner paying 25% of the disputed tax. The petitioner also sought release of attachments over its bank accounts.

Whether the assessment order should be set aside and the matter remitted where the notices were uploaded to the GST portal, but no personal hearing was provided.

Whether the bank-account attachment could continue after the assessment order was set aside.

Section 169(1) of the GST Act provides for recognised modes of service of notices and other communications; portal service is a valid mode.

However, where a taxpayer does not respond to portal notices, the issuing officer should consider other available modes of service, preferably registered post with acknowledgment due, to ensure effective notice. An assessment made without a personal hearing may be remitted for fresh consideration, subject to appropriate conditions.

The Court accepted that uploading notices to the GST portal constituted valid service, but considered that the absence of any response should have prompted the officer to explore other modes permitted by Section 169(1), rather than proceed on portal service alone.

The assessment was also made without a personal hearing, a fact acknowledged by the respondent. In light of these circumstances and the petitioner’s undertaking to pay 25% of the disputed tax, the Court set aside the assessment and remitted the matter. Because the assessment order was set aside, the consequential bank-account attachment could not continue.

The petitioner was directed to file its reply and supporting documents within three weeks of payment. The respondent must then provide 14 clear days’ notice of a personal hearing and decide the matter on its merits and in accordance with law. Respondents 2 and 3 were directed to release the bank attachment and defreeze the accounts upon production of the order and proof of payment. No costs were ordered.