Effective communication of show-cause notices is essential; portal-only uploads can breach natural justice and require fresh adjudication.

Mere uploading of a show-cause notice and reminders on a portal, without official communication to the assessee, does not provide an effective opportunity to respond. Such failure denies a meaningful hearing and breaches the principles of natural justice. The notes state that writ jurisdiction may be exercised despite an alternative statutory appellate remedy where the notice was not effectively communicated. The assessment order was set aside, with the assessee permitted to respond to the show-cause notice and receive an oral hearing before fresh adjudication.

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Issues: Whether the assessee was required to pursue the statutory appellate remedy despite lack of effective communication of the show-cause notice and consequent denial of an opportunity of hearing.

Analysis: Mere uploading of the show-cause notice and reminders on the portal, without official communication to the assessee, did not afford an effective opportunity to respond. The absence of such opportunity constituted a violation of the principles of natural justice, warranting exercise of writ jurisdiction notwithstanding the alternative appellate remedy.

Conclusion: The assessment order was set aside for breach of the principles of natural justice, and the assessee was permitted to reply to the show-cause notice and receive an oral hearing before fresh adjudication.

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