Natural justice breached where show cause notice was not served at updated GST contact details; recovery notice quashed.

Where a show cause notice was not shown to have been served on the taxpayer's updated registered address or registered email ID, the resulting adjudication order was vitiated for breach of natural justice. The record did not establish effective service or a meaningful pre-decisional hearing, and the court held that an adverse order cannot stand without observance of audi alteram partem. The impugned order and recovery notice were quashed, and fresh adjudication was directed after issuance of a new show cause notice and grant of personal hearing.

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Issues: Whether the impugned order and recovery notice were liable to be quashed for non-service of the show cause notice at the correct registered address and registered email ID, resulting in denial of opportunity of hearing and breach of natural justice.

Analysis: The petitioner's registered address and email IDs had been updated on the GST registration and portal, yet the show cause notice was not shown to have been served on those particulars. The record did not substantiate effective service on the correct address or email ID. The consequent order was therefore passed without affording a pre-decisional hearing. Such a course vitiates the proceedings, since no adverse order can be sustained without observance of the audi alteram partem rule.

Conclusion: The impugned order and the recovery notice were quashed and set aside, and fresh adjudication was directed after issuance of a new show cause notice and grant of personal hearing.

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