Reasoned tax adjudication and fair hearing are mandatory; summary GST orders and consequential bank attachment could not survive.

A reasoned adjudication order under the WBGST Act must record the relevant facts and basis of decision and be preceded by a fair hearing. A summary order lacking particulars, reasons, and an opportunity of hearing violates statutory requirements and natural justice, and cannot sustain civil consequences under writ review. Service of notices and orders only through the GST portal's additional notices and orders tab was treated as improper where the show cause notice did not contain sufficient factual detail for a meaningful reply. Consequential bank attachment founded on the invalid order could not survive, and fresh proceedings were permitted from the stage of a detailed show cause notice.

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Issues: (i) Whether an adjudication order passed in summary form without relevant facts, reasons, and hearing could be sustained in law; (ii) whether service of notices and orders through the "additional notices and orders" tab on the GST portal was proper and whether the consequential bank attachment could survive.

Issue (i): Whether an adjudication order passed in summary form without relevant facts, reasons, and hearing could be sustained in law.

Analysis: Section 75(6) of the WBGST Act, 2017 requires the proper officer to set out the relevant facts and the basis of the decision in the adjudication order. An order passed by a quasi-judicial authority must also be informed by reasons. Where the order communicated to the taxpayer remains in summary form, contains no factual particulars, and is passed without affording the required hearing under Section 75(4), the order violates the statutory mandate and the principles of natural justice. An order without reasons cannot withstand scrutiny under Article 226 of the Constitution of India, particularly when civil consequences follow.

Conclusion: The adjudication order was unsustainable and was set aside.

Issue (ii): Whether service of notices and orders through the "additional notices and orders" tab on the GST portal was proper and whether the consequential bank attachment could survive.

Analysis: Notice and order service through the "additional notices and orders" tab on the GST portal was treated as improper. Since the show cause notice lacked the factual and other details necessary for a meaningful reply, the proceedings could not be allowed to stand on that basis. The bank attachment was founded on the impugned adjudication order, and once that order failed, the attachment could not be retained.

Conclusion: The writ petition was entertained, the consequential bank attachment was lifted, and fresh proceedings were permitted from the stage of a detailed show cause notice.

Final Conclusion: The impugned tax adjudication was annulled for want of reasons and denial of hearing, consequential coercive action was withdrawn, and the matter was remitted for fresh adjudication in accordance with law.

Ratio Decidendi: A quasi-judicial tax adjudication must be a reasoned speaking order complying with the statutory requirement to record facts and the basis of decision and must be preceded by a fair opportunity of hearing; a summary, unreasoned order passed in breach of natural justice cannot be sustained, and consequential enforcement action based on it must also fall.

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