Natural justice in GST proceedings requires effective notice after registration cancellation; portal-only service was held insufficient.

An order under Section 73 of the Uttar Pradesh GST Act could not be sustained where the show-cause notice was uploaded only on the GST portal after cancellation of registration, because the taxpayer was no longer obliged to monitor that portal and effective notice was not ensured. Service had to be made by an alternative proper mode to satisfy fair hearing requirements. The HC quashed the order for breach of natural justice, while leaving the department free to issue a proper notice and proceed in accordance with law.

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Issues: Whether an order passed under Section 73 of the Uttar Pradesh Goods and Services Tax Act, 2017 could be sustained when the show-cause notice was uploaded only on the GST portal after cancellation of the taxpayer's registration, thereby denying effective notice.

Analysis: The registration had already been cancelled, and the taxpayer was not obliged to keep checking the GST portal thereafter. In such circumstances, service of notice had to be effected through an alternative and proper mode. Since the impugned order was founded on notice served only through the portal, the procedure adopted did not satisfy the requirements of fair hearing and compliance with natural justice.

Conclusion: The impugned order was quashed and set aside for violation of natural justice, and the department was left at liberty to issue a proper notice and proceed in accordance with law.

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