Service irregularity and interim deposit in tax dispute; court orders Rs 25 lakh deposit to secure revenue.

Alleged procedural irregularity in service and summary adjudication was examined; incomplete production of email extracts about notices led the court to treat service reliability as disputed and justify protective measures. To secure the public revenue and protect a vulnerable respondent, the court directed an interim deposit of Rs. 25,00,000 by the petitioner's director or her son within 30 days; failure to deposit authorises respondents to treat the petition as dismissed in limine and take further steps against the son. The writ petition was disposed with those conditions.

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Issues: Whether a writ petition challenging the Order-in-Original dated 30.07.2025 on the ground of non-receipt of the Show Cause Notice can be finally adjudicated in a summary proceeding and whether interim security in the form of a deposit should be directed to protect the revenue pending challenge.

Analysis: The issue of service of notice and receipt of communications cannot be conclusively determined in a summary admission-stage proceeding. Relevant documentary proof of email communications or inbox status was not produced by the petitioner. Material facts include that the petitioner's director has left the business and the country, which affects the ability to secure recovery. In these circumstances, protecting the fiscal interest requires an interim measure. Hence a quantifiable deposit was directed to secure the disputed tax while the challenge proceeds.

Conclusion: Direction issued for deposit of Rs. 25,00,000 within 30 days by the petitioner (represented by its director and her son) as interim security; failure to deposit permits respondents to treat the writ petition as dismissed in limine and to proceed with recovery steps including extradition measures against the son.

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