GST notice service by registered email upheld; writ not entertained where statutory appeal was available.

Service of GST notices sent to the registered e-mail address and mobile number satisfied Section 169 of the CGST Act, 2017, and the Court applied the principle that electronic communication is received when it enters the designated computer resource under Section 13 of the Information Technology Act, 2000. On the record of repeated notices before ex parte assessment, there was no breach of natural justice. Because an efficacious statutory appeal was available under Section 107, writ jurisdiction was not to be invoked absent a recognised exception to the alternate-remedy rule. The challenge to the assessment and consequential freezing action was therefore left to be pursued before the appellate authority.

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Issues: Whether the writ petition was maintainable despite the statutory appeal under Section 107 of the Central Goods and Services Tax Act, 2017, and whether service of notices through the registered e-mail address satisfied Section 169 of the Central Goods and Services Tax Act, 2017 so as to negate any plea of violation of natural justice.

Analysis: The statutory scheme permits service by several modes, including communication to the e-mail address provided at registration, and the judgment also applied the principle under Section 13 of the Information Technology Act, 2000 that electronic communication is received when it enters the designated computer resource. The notices and assessment communications were sent to the e-mail address and mobile number furnished at registration, and the record showed repeated notices before the ex parte assessment. In these circumstances, the Court held that service was in accordance with Section 169 and that there was no violation of natural justice. Since an efficacious appellate remedy under Section 107 was available, the writ jurisdiction was not to be invoked in the absence of any established exception to the alternate-remedy rule.

Conclusion: The writ petition was not maintainable, and the petitioner was relegated to the statutory appeal remedy.

Final Conclusion: The challenge to the assessment and consequential freezing action was left to be pursued before the appellate authority, and the High Court declined to entertain the writ jurisdiction.

Ratio Decidendi: Where service of GST notices is effected through the registered e-mail address in terms of the statutory modes of service, and an efficacious statutory appeal is available, a writ petition will not be entertained absent a demonstrated exception such as violation of natural justice or lack of jurisdiction.

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