Ineffective service of GST show cause notice on portal defeated natural justice and required remand for fresh adjudication.

Where a show cause notice remained accessible only on the GST portal's 'Additional Notices Tab' and was not brought to the taxpayer's knowledge, service was ineffective and no meaningful opportunity to reply arose. A reminder uploaded in the same manner did not cure the defect because the original notice was never effectively served. An ex parte demand based on such notice was therefore unsustainable for breach of natural justice, and the proper course was to set aside the demand and remand the matter for fresh adjudication after filing of reply and grant of personal hearing.

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Issues: Whether the show cause notice uploaded only on the 'Additional Notices Tab' was effectively served on the petitioner, and whether the impugned demand order was liable to be set aside and the matter remanded for fresh adjudication after granting opportunity of reply and personal hearing.

Analysis: The SCN was issued prior to the portal changes that made the 'Additional Notices Tab' visible, and no reply was filed because the notice was not brought to the petitioner's knowledge. A subsequent reminder in respect of the same notice, also uploaded in the same tab, did not cure the defect because the original SCN had not been effectively served. The absence of an effective opportunity to contest the SCN and the resulting ex parte demand made the adjudication unsustainable. The proper course was to set aside the demand and restore the matter to the adjudicating authority for consideration on merits after filing of reply and grant of hearing.

Conclusion: The impugned order was set aside and the matter was remanded for fresh adjudication after permitting the petitioner to file reply and after granting a personal hearing.

Ratio Decidendi: Where a show cause notice is not effectively served because it remains inaccessible on the GST portal, any ex parte adjudication based on such notice violates natural justice and must be set aside for fresh decision after due hearing.

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