Service of GST notices must follow statutory modes, not portal-only delivery, to satisfy natural justice and valid notice requirements.

Section 169 of the Tamil Nadu GST Act was construed as a complete code for service of notices, summons and orders, requiring authorities to use the statutory modes in the prescribed sequence rather than relying on the common portal alone. The court held that clauses (a) to (c) provide direct modes of service, while clauses (d) to (f) apply when earlier modes are not practicable, and that subordinate rules cannot narrow the broader service methods in the Act. The provision was applied to secure strict compliance with natural justice. Service only through the portal was found insufficient, and the assessments were set aside with liberty to proceed afresh after proper notice and hearing.

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Issues: Whether service of notices, summons and orders under Section 169 of the Tamil Nadu Goods and Services Tax Act, 2017 could be confined to the common portal alone, and whether the provision required the statutory modes of service to be read conjunctively so as to ensure compliance with natural justice.

Analysis: Section 169 was read as a complete scheme for service of communications. The modes specified in clauses (a) to (c) were treated as alternative modes of direct service, registered post or e-mail, while clauses (d) to (f) operated as further alternatives where the earlier modes were not practicable. The Court compared Section 169 with the earlier service provision under Rule 52 of the TNGST Rules, 1959 and held that the structure of the provision showed a statutory preference for effective service in the listed sequence, rather than service through the portal as the sole mode. Rules could not curtail the broader statutory modes provided by the Act. The object of the provision was held to be strict observance of natural justice.

Conclusion: Service only through the portal was held to be insufficient where the statutory modes under Section 169 were not followed in the manner required by law, and the impugned assessment orders were set aside with liberty to proceed afresh after proper notice and hearing.

Final Conclusion: The writ petitions succeeded and the assessments were remitted for fresh consideration after lawful service and opportunity of hearing.

Ratio Decidendi: Where a taxing statute prescribes multiple modes of service, the authorities must adopt the statutorily effective modes in a manner that secures natural justice, and subordinate rules cannot be used to narrow the statutory requirement.

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