Natural justice in GST adjudication requires effective notice; portal-only service after cancellation of registration was insufficient.

An adjudication order was set aside for breach of natural justice because the taxpayer's GST registration had already been cancelled, no revival was sought or made, and notices were issued only through the GST portal without physical or offline service. In those circumstances, the court held that service through e-mode alone did not satisfy the requirement of a fair hearing. The taxpayer was permitted to file a reply to the show cause notice, and the matter was directed to be decided afresh after granting personal hearing.

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Issues: Whether the adjudication order was liable to be set aside for breach of natural justice, where the petitioner's GST registration had already been cancelled, no revival was sought or made, notices were issued only through the GST portal, and no physical notice was served before passing the impugned order.

Analysis: The petitioner's registration stood cancelled long before the adjudication order, and the record did not show any revival of that registration. In those circumstances, the petitioner was not required to access the GST portal for e-mode notices. The absence of any physical or offline service of notice before passing the order showed that the essential requirement of a fair hearing had not been satisfied. In view of these facts, relegation to an alternate remedy or continuation of the writ proceedings was found unnecessary.

Conclusion: The impugned order was set aside for breach of natural justice, and the petitioner was permitted to file a reply to the show cause notice followed by a fresh decision after granting personal hearing.

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