Effective portal communication of tax orders required before demand is sustained; assessee given fresh chance to reply and be heard.

Effective communication of an adjudication order through the portal is necessary before adverse demand consequences are sustained. Where the assessee showed that the order appeared on a different tab from the one ordinarily used for viewing notices and orders, and no material rebutted that grievance, the Court required a fresh opportunity to reply rather than forcing the assessee into a separate statutory remedy. It directed that the assessee treat the impugned order as the final notice, file a written reply within two weeks, and that the assessing officer issue a fresh notice with at least fifteen days' notice before passing a reasoned and speaking order within one month.

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Issues: Whether the impugned order and demand could be sustained when the assessee alleged that the order was not properly communicated on the portal, and whether a fresh opportunity of reply and adjudication was required.

Analysis: The order was stated to be reflected on a tab different from the one ordinarily used for viewing notices and orders, and no material was shown to discredit the assessee's grievance on communication. In the circumstances, the Court considered it to avoid keeping the petition pending or driving the petitioner to a separate statutory remedy, especially when the disputed amount already stood deposited. The Court therefore directed the assessee to treat the impugned order as the final notice, submit a written reply within two weeks, and required the assessing officer to issue a fresh notice with clear notice of at least fifteen days and thereafter pass a reasoned and speaking order within one month.

Conclusion: The petition was disposed of with directions for a fresh notice, fresh reply, and a reasoned adjudication, thereby granting relief to the assessee on the issue of effective communication and opportunity of hearing.

Ratio Decidendi: Where an adjudication order is not shown to have been effectively communicated through the portal in the manner expected, the assessee should be afforded a fresh opportunity to respond before a reasoned and speaking order is passed.

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