Effective notice under GST portal service fails after registration cancellation; assessment order quashed for breach of natural justice.

Where a dealer's GST registration had already been cancelled, service of a show cause notice only through the GST portal was not effective notice and did not satisfy natural justice, because the dealer was no longer expected to keep checking the portal. The assessment order passed under Section 73 of the Uttar Pradesh GST Act was therefore vitiated by defective service and denial of a fair opportunity. The Allahabad HC quashed and set aside the order, while leaving the department free to proceed afresh in accordance with law after proper notice.

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Issues: Whether the assessment order passed under Section 73 of the Uttar Pradesh Goods and Services Tax Act, 2017 was liable to be quashed for breach of natural justice where the petitioner's registration had already been cancelled and notice was uploaded only on the GST portal.

Analysis: Once registration stood cancelled, the petitioner was not expected to keep checking the GST portal. In such circumstances, service of the show cause notice through the portal alone was inadequate, and notice had to be served through an alternative effective mode. The impugned order was therefore founded on defective service and resulted in denial of a fair opportunity.

Conclusion: The impugned order was quashed and set aside for violation of the principles of natural justice, and the petitioner succeeded on this issue.

Final Conclusion: The matter was disposed of after setting aside the assessment order and leaving the department free to proceed afresh in accordance with law after proper notice.

Ratio Decidendi: Where a dealer's registration has been cancelled, service of a show cause notice only through the GST portal does not constitute effective notice; an alternative and proper mode of service is required to satisfy natural justice.

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