GST limitation and deemed service dispute kept open where portal availability was said not to equal communication.

A writ petition challenged dismissal of a GST appeal as time-barred on the ground that the underlying order had not been communicated, and that mere availability on the portal did not necessarily amount to deemed service. The court noted the distinction between "communicated" and "served" under the GST service provisions, required the State to explain how service could be treated as deemed service under the relevant deeming clause, and called for a counter affidavit. The limitation and service questions were left open for further consideration, and interim protection was granted against coercive recovery on deposit of part of the disputed tax.

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Issues: Whether the dismissal of the petitioner's appeal as time-barred was sustainable in view of the contention that the order was not communicated to the petitioner and that mere making it available on the portal did not amount to deemed service under the GST regime.

Analysis: The writ petition assailed the appellate order rejecting the appeal on limitation and raised the distinction between "communicated" and "served" in the GST provisions. The Court found that the matter required consideration, called for a counter affidavit, and directed the State to explain the manner in which service under the relevant clauses of the service provision could be treated as deemed service under the deeming clause.

Outcome: Noticeable issues regarding limitation and service were kept open for further consideration, and interim protection was granted against coercive action on deposit of part of the disputed tax.

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