Natural justice in GST adjudication requires effective notice; portal-only service was insufficient where registration remained suspended.

Where GST registration remained suspended and had not been revived, service of adjudication notice only through the GST portal was not effective because the taxpayer could not reasonably be expected to access e-mode notices. As no physical or offline notice was shown to have been served before the impugned order, the requirement of fair procedure and opportunity of hearing was not met. The HC set aside the adjudication order and remitted the matter for fresh decision after treating the order as notice, allowing reply and granting personal hearing.

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Issues: Whether the adjudication order passed without physical or offline service of notice, when the GST registration stood suspended and was not revived, violated the principles of natural justice and warranted setting aside of the order.

Analysis: The registration of the petitioner under the UPGST Act, 2017 remained suspended and had not been revived. In those circumstances, the petitioner was not expected to access the GST portal for e-mode notices. No physical or offline notice was shown to have been served before the impugned order. In the absence of effective notice and an opportunity of hearing, the statutory requirement of fair procedure was not satisfied, and no purpose would have been served by keeping the petition pending or relegating the petitioner to an alternative remedy.

Conclusion: The adjudication order was set aside and the matter was remitted for fresh decision after treating the impugned order as notice, permitting reply and affording personal hearing.

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