Valid portal service and non-response defeat a hearing-opportunity challenge to a tax determination order.

A tax determination order was not interfered with because the taxpayer had received a show cause notice and repeated reminders but failed to respond or attend a personal hearing. Notice served through the statutory portal was treated as valid service, and a business regularly carrying on trade could not claim ignorance of such notices. Non-response to notices was held to be different from denial of an opportunity by the authority, so the challenge based on breach of hearing opportunity failed and writ interference was declined.

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Issues: Whether the impugned tax determination order could be interfered with on the ground of alleged denial of opportunity of hearing.

Analysis: The petitioner had been issued a show cause notice and repeated reminders, yet did not respond or avail the opportunity for personal hearing. A notice served through the statutory portal is a valid mode of notice, and a party carrying on regular business cannot claim ignorance of such notices. Failure to respond to the notices is distinct from denial of an opportunity by the authority.

Conclusion: The challenge on the ground of breach of hearing opportunity failed, and the writ court declined interference under Article 226 of the Constitution of India.

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