Physical service of GST adjudication notice required after cancellation of registration; portal-only service violates natural justice.

After cancellation of GST registration, an adjudication notice cannot validly be served only through the Common Portal because the registered person is no longer effectively able to access it in the ordinary course. Service must be made physically under Section 169(1)(a)(b) of the Uttar Pradesh GST Act, 2017. Failure to effect physical service deprived the taxpayer of a real opportunity to object and reply, constituting a substantial breach of natural justice and the hearing requirement under Section 75(4). The adjudication order was therefore unsustainable, and fresh adjudication was directed after proper physical notice and opportunity of hearing.

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Issues: Whether an adjudication notice issued after cancellation of GST registration could validly be served only through the Common Portal, and whether failure to serve it physically vitiated the adjudication order for breach of natural justice.

Analysis: After cancellation of registration, the registered person is no longer effectively able to access or monitor the Common Portal in the ordinary course. In such circumstances, service of an adjudication notice after cancellation must be effected physically in terms of Section 169(1)(a)(b) of the Uttar Pradesh Goods and Services Tax Act, 2017. The absence of such physical service deprived the petitioner of a real opportunity to file objections and reply, amounting to a substantial violation of natural justice. The right to be heard is also protected by Section 75(4) of the Uttar Pradesh Goods and Services Tax Act, 2017.

Conclusion: The adjudication order was unsustainable and was set aside. The matter was remitted for fresh adjudication after physical notice and opportunity of hearing, in favour of the petitioner.

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