Invalid service of show cause notice on portal tab led to setting aside adjudication and remand for fresh hearing.

Uploading a show cause notice only under the portal tab for additional notices and orders was treated as insufficient service because it made the notice less accessible to the taxpayer and conflicted with earlier binding precedent on statutory service. As the notice was issued before the portal redesign, the adjudication order based on that notice could not stand without a proper opportunity to respond. The impugned order was set aside and the matter remanded for fresh adjudication after considering the petitioner's reply and granting a hearing.

---

---

Issues: Whether a show cause notice uploaded only under the portal tab for additional notices and orders constituted valid service, and whether the adjudication order passed on that basis could be sustained.

Analysis: The portal categorisation made the notice less accessible to the taxpayer, and the issue had already been addressed in earlier binding precedent which held that such uploading did not amount to sufficient service under the statutory scheme. Since the notice in the present matter was issued before the portal was redesigned, the impugned adjudication could not be sustained without giving the petitioner a proper opportunity to respond to the notice.

Conclusion: The impugned order was set aside and the matter was remanded for fresh adjudication of the show cause notice after considering the petitioner's response and granting an opportunity of hearing.

---