Service by Portal does not suffice; lack of statutory opportunity to be heard vitiates the order and warrants interim stay.

Uploading an adjudication order to an 'additional notices and orders' portal does not constitute valid service; effective service is required to trigger limitation and enforcement. An adjudication order rendered without affording the statutory opportunity under Section 75(4) is procedurally vitiated. Where there is a strong arguable case on service and denial of the opportunity to be heard, interim relief restraining recovery measures and requiring lifting of bank attachment is appropriate pending final disposal of the writ petition.

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Issues: (i) Whether uploading of notices and orders on the portal under the "additional notices and orders" tab constitutes valid service; (ii) Whether the adjudication order supported by Notification No.56 of 2023-Central Tax and corresponding State notification, and passed without affording opportunity under Section 75(4), is vitiated and whether interim relief restraining recovery and lifting bank attachment should be granted.

Issue (i): Whether uploading of notices and orders on the portal under the "additional notices and orders" tab amounts to proper service of the adjudication order.

Analysis: The Court considered precedent of the Division Bench in Ram Kumar Sinhal which holds that mere uploading under the stated portal is not equivalent to proper service. The petitioner's lack of knowledge of the impugned order until receipt of a recovery notice and the manner of publication were evaluated in light of the requirement of effective service to trigger limitation and enforcement steps.

Conclusion: Uploading of the adjudication order on the portal under the "additional notices and orders" tab does not constitute proper service.

Issue (ii): Whether the adjudication order premised on Notification No.56 of 2023-Central Tax and the corresponding State notification and passed without opportunity under Section 75(4) is vitiated and whether interim relief should issue.

Analysis: The petitioner challenged the vires of the notifications under Section 168A and asserted denial of opportunity under Section 75(4). The Court found a strong arguable case on the challenge to service and on the procedural defect arising from non-compliance with Section 75(4). Given the substantial question on validity and the procedural infirmity affecting the order's legitimacy, the Court considered balance of convenience and potential prejudice, and observed that recovery steps flowing from the impugned order should be restrained pending disposal of the writ petition.

Conclusion: The adjudication order is vitiated by the procedural defect of not affording opportunity under Section 75(4), and interim relief is warranted; the respondent authorities are restrained from recovering any amount under the impugned order and shall lift the bank attachment.

Final Conclusion: The petitioner has made out a strong arguable case on service and procedural grounds, justifying interim protection against recovery and attachment until final adjudication of the writ petition.

Ratio Decidendi: Where an adjudication order affecting a taxpayer is not validly served (mere uploading under an "additional notices and orders" portal is not proper service) and the order is passed without compliance with the statutory requirement to afford an opportunity under Section 75(4), the order is vitiated in procedure and interim relief restraining recovery and ancillary attachments is appropriate pending final determination.

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