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

The petitioner challenged assessment orders dated 27 December 2023 and 20 August 2024, concerning GST assessment years 2017–18 and 2019–20, together with consequential DRC-07 and DRC-08 summaries.

He submitted that notices had been uploaded under “View Additional Notices and Orders” on the GST portal, of which he was unaware, and that the orders were made without a personal hearing.

The State accepted that no personal hearing had been provided and sought remittal for fresh consideration.

The petitioner’s bank accounts had also been attached.

Whether the assessment orders should be set aside where the petitioner had not responded to notices uploaded on the GST portal and no personal hearing was provided

Whether the bank-account attachment could continue after the impugned orders were set aside

Section 169 of the GST Act recognises prescribed modes of service, including service through the GST portal and other permitted modes.

Although portal upload constitutes a valid mode of service, where a taxpayer does not respond to notices sent through that mode, the officer should consider using other available modes—preferably registered post with acknowledgment due—to make service effective.

The requirement to provide a personal hearing and the principles of natural justice also informed the Court’s decision; no precedent was cited.

The Court noted that the notices had been uploaded on the GST portal but accepted that the petitioner claimed not to have known of them and that the original notices had not been furnished.

While portal service was legally sufficient, the lack of response should have prompted the officer to explore other modes of service under Section 169, rather than proceed to ex parte orders.

The absence of a personal hearing—also acknowledged by the State—supported setting aside the orders and remitting the matters for fresh consideration.

Because the underlying orders were set aside, the attachment could no longer be sustained.

The petitioner was directed to file objections and supporting documents within four weeks of receiving the order; the officer must then give 14 days’ clear notice fixing a personal hearing and pass fresh orders on the merits.

The first respondent was directed to lift the bank attachment, with liberty for the petitioner to produce the Court’s order directly to the banks if the lifting was not communicated.

The writ petitions were disposed of without costs.