GST assessment reopened for fresh objection hearing after ineffective portal notice, subject to deposit condition.

Assessment proceedings uploaded only under the GST portal's additional notices and orders tab were treated as having denied effective notice and participation, so the matter was reopened for fresh consideration. The High Court accepted that the assessee should get one final opportunity to file objections and directed that the assessment order be treated as a show cause notice after compliance with a deposit condition. The relief was made conditional on deposit of 25% of the disputed tax within the stipulated time, after which the objections would be heard afresh; failing compliance, the assessment order would stand restored.

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Issues: Whether the assessment order could be set aside for want of effective opportunity and whether the matter should be restored for fresh consideration on compliance with the stipulated deposit condition.

Analysis: The impugned assessment was challenged on the ground that the notices and order were uploaded only under the additional notices and orders tab on the GST portal, resulting in lack of awareness and absence of participation in the adjudication. The petitioner sought one final opportunity to place objections, and the respondents did not seriously oppose that course. The Court accepted this submission and coupled the relief with a condition to deposit 25% of the disputed tax, after which the assessment order would be treated as a show cause notice and the objections would be considered afresh after hearing.

Conclusion: The impugned order was set aside and the petitioner was granted an opportunity to contest the proposal subject to deposit of 25% of the disputed tax within the stipulated time, failing which the assessment order would stand restored.

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