GST portal service without alert may satisfy notice rules, but fresh assessment was ordered for lack of due notice.

Portal-upload of GST notices and assessment orders may satisfy service requirements, but where no alert intimation is sent and the registered person claims non-receipt, the process must still comply with natural justice and the procedural safeguards under GST law. On the facts, the notices and orders were only uploaded on the portal and were not otherwise brought to the petitioner's attention, so the assessment orders were set aside. The matters were remanded to the proper officer for fresh assessment after due notice, subject to payment of 20% of the disputed tax within six weeks.

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Issues: Whether uploading the notices and assessment orders on the portal without any alert to the registered person constituted sufficient service, and whether the assessment orders were liable to be set aside and the matters remanded for fresh assessment after due notice.

Analysis: The challenge arose from the petitioner's claim that the assessment notices and orders were not actually received and were known only after attachment proceedings were initiated. The Court accepted that mere portal-uploading may amount to service in terms of the applicable GST framework, but emphasised that cases involving portal service without alerts have caused hardship to registered persons lacking adequate technical assistance. In the present facts, the notices and assessment orders were only uploaded on the portal, without alert intimation to the petitioner. To balance revenue interests with fairness, the Court held that the proceedings had to conform to the principles of natural justice and the procedural requirements under the GST law.

Conclusion: The assessment orders were set aside and the matters were remanded to the proper officer for fresh orders after due notice to the petitioner, subject to payment of 20% of the disputed tax within six weeks.

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