Email service of assessment order upheld; belated appellate relief refused as time-barred challenge could not be revived.

Service of an assessment order by email was treated as valid under Rule 64 of the Andhra Pradesh Value Added Tax Rules, 2005, as amended, and the dealer could not avoid service by claiming the email account had become inactive without informing the assessing authority of any change. The Court also refused to direct issuance of a certified copy merely to enable a belated appeal, because such relief would effectively revive a time-barred challenge. Reliance on possible production of F Forms in appeal did not alter that position. The writ petition was dismissed and the assessment order left undisturbed.

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Issues: Whether service of the assessment order by email was valid and whether the petitioner could be permitted to obtain a certified copy and file an appeal at the belated stage.

Analysis: The assessment year in question had already lapsed, the assessment order was stated to have been served through email, and the petitioner's first request for a certified copy was made only much later. Rule 64 of the Andhra Pradesh Value Added Tax Rules, 2005, as amended, recognised service by email as a valid mode of service. The plea that the email address had become inactive was not accepted, as the dealer was expected to keep the assessing authority informed of any change in the email address. The Court also found no basis to direct issuance of a certified copy merely to revive a limitation-barred appeal, and the reliance on the possibility of producing F Forms in appeal did not assist the petitioner at this stage.

Conclusion: Service by email was held to be valid, the request to facilitate a belated appeal was rejected, and the challenge failed.

Final Conclusion: The writ petition was dismissed, and the assessment order was not interfered with.

Ratio Decidendi: Where the governing rule recognises email as a valid mode of service, a dealer cannot avoid service or extend limitation merely by alleging that the email account had become inactive, and belated appellate relief cannot be granted to revive a time-barred challenge.

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