GST assessment service through portal upload requires meaningful opportunity to respond before fresh adjudication.

Assessment under the GST regime based only on portal-uploaded notices and order was found vulnerable where the taxpayer was denied a meaningful opportunity to respond. The Court balanced portal-based service against practical access difficulties and the requirement of natural justice, holding that procedural fairness required a proper hearing before fresh adjudication. The impugned assessment order was set aside and the matter remanded for reconsideration after due opportunity to the petitioner, subject to payment of 20% of the disputed tax within the stipulated period.

---

---

Issues: Whether the assessment order passed under the GST regime could be sustained when the notices and order were only uploaded on the portal and the petitioner was denied a meaningful opportunity to respond.

Analysis: The assessment was challenged on the ground of lack of effective service and violation of natural justice. The Court noted that while portal-based uploading had earlier been treated as sufficient service, the practical difficulty faced by assessees who are not technically equipped warranted a balancing approach. To protect revenue as well as procedural fairness, the Court held that the petitioner should be afforded a proper opportunity before fresh adjudication.

Conclusion: The impugned assessment order was set aside and the matter was remanded for fresh consideration after due opportunity to the petitioner, subject to payment of 20% of the disputed tax within the stipulated period.

---