Uploading a GST Show-Cause Notice Only Under “Additional Notices and Orders” Violates Natural Justice.

The petitioner challenged an adjudication order dated 9 December 2025.

It submitted that the show-cause notice in Form DRC-01, dated 19 September 2025, had been uploaded only under the GST portal’s “Additional Notice and Orders” tab, without separate intimation, and that it consequently did not respond.

The petitioner said it discovered the adjudication order when its accountant checked the portal in April 2026.

The State opposed the petition, contending that the petitioner had received ample opportunity and that its appeal had been dismissed as time-barred.

The judgment records the impugned order as dated 9 December 2025 in the relief granted, although it refers to a different date in its account of the petitioner’s submission.

Whether uploading the show-cause notice only under the portal’s “Additional Notice and Orders” tab, without separate intimation, denied the petitioner an effective opportunity to respond and violated natural justice.

Whether the adjudication order should be quashed and the matter remitted for fresh adjudication after giving the petitioner an opportunity to reply and be heard.

The Court applied the principles of natural justice, particularly the requirement that a person facing adjudication receive effective notice and a meaningful opportunity to respond.

The judgment does not identify any specific statutory provision or precedent; its stated basis for intervention is that the notice’s placement on the portal, without separate intimation, prevented the petitioner from replying and constituted a violation of natural justice.

The Court found that the petitioner had made out a prima facie case.

It accepted that the show-cause notice had been uploaded only under the “Additional Notice and Orders” tab and that no separate intimation had been given.

In the Court’s view, this explained the petitioner’s failure to respond and amounted to a breach of natural justice.

Considering the circumstances, it held that interference was warranted.

It directed the petitioner to reply to the show-cause notice within two weeks of communication of the order; respondent No. 3 must provide a personal hearing and pass a fresh, reasoned order within 12 weeks, with the decision communicated to the petitioner within a further week.

The writ petition was disposed of accordingly.