Unanswered GST portal notices require alternative Section 169 service efforts before ex parte assessment.

The petitioner challenged a Form GST DRC-07 order dated 20 March 2026 and sought, consequentially, de-freezing of its bank account.

The petitioner said notices had been uploaded on the GST portal, which it had not monitored, and that the assessment order was passed without a personal hearing; it was willing to pay 25% of the disputed tax to have the matter reconsidered.

The respondent acknowledged that no personal hearing had been afforded and agreed to remand subject to payment of 25% of the disputed tax.

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

2. Whether the attachment of the petitioner’s bank account could continue after the assessment order was set aside.

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

The Court also applied the requirement of affording a personal hearing before deciding the matter, as reflected in its finding that the impugned order had been passed without such an opportunity.

No judicial precedents were cited.

Although the show-cause notice had been uploaded to the GST portal, the petitioner said it was unaware of the notice, and the respondent conceded that no personal hearing had been provided.

The Court considered portal service legally valid but held that, in the absence of any response to repeated notices, the officer should have explored other modes under Section 169(1), rather than treating portal upload as an empty formality.

In light of the procedural deficiency and the petitioner’s willingness to pay 25% of the disputed tax, the Court set aside the order and remanded the matter.

Because the underlying order was set aside, the bank-account attachment could not continue.

The petitioner must file its reply and supporting documents within three weeks of payment.

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

The bank was directed to de-freeze the account immediately upon production of the Court’s order and proof of payment.

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