Natural justice in GST demands effective notice after registration cancellation; ineffective service vitiated the proceedings.

Where GST registration had already been cancelled, the taxpayer was not expected to keep checking the portal, so a show cause notice had to be served by an alternative and proper mode. Because the notice was not effectively served, the proceedings under Section 73 were vitiated for breach of natural justice. The Court quashed the assessment order and consequential recovery certificate, while permitting the Department to issue a fresh notice and proceed in accordance with law.

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Issues: Whether the assessment order and consequential recovery proceedings were liable to be quashed for breach of natural justice when no show cause notice was served after cancellation of registration.

Analysis: The registration had already been cancelled, and the petitioner was therefore not expected to keep checking the GST portal. In such a situation, service of notice had to be made by an alternative and proper mode. Since the show cause notice was not effectively served, the proceedings under Section 73 were vitiated. The reasoning was consistent with the principle that a person must be afforded a fair opportunity before an adverse order is passed.

Conclusion: The impugned order and the consequential recovery certificate were quashed and set aside for violation of natural justice, and the Department was permitted to issue a fresh notice and proceed in accordance with law.

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