GST portal service and natural justice concerns led to conditional remand after partial tax deposit.

Uploading notices on the GST portal was treated as valid service, but complaints of non-service and lack of actual knowledge led the Court to grant one further opportunity in the interest of natural justice. The assessment orders were set aside and the matters remanded for fresh assessment, subject to deposit of 20% of the disputed tax within the stipulated time. The writ period was directed to be excluded for limitation purposes, and all issues were left open before the Assessing Authority.

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Issues: Whether the assessment orders deserved interference on the ground of non-service of notices and violation of natural justice, and whether the petitioners were entitled to a fresh opportunity subject to deposit of part of the disputed tax.

Analysis: The writ petitions arose from assessment orders challenged by registered GST assessees who asserted that notices and orders had not been effectively served. The order notes the contention that uploading on the GST portal constitutes valid service under the GST framework and records the view that such mode of service is sufficient. At the same time, in light of complaints regarding non-service and the possibility that registered persons or their representatives may not have actual knowledge of portal uploads, the Court considered it appropriate to grant one further opportunity. That relief was made conditional upon deposit of 20% of the disputed tax within the stipulated time. The Court also directed exclusion of the writ period for limitation purposes and left all issues open before the Assessing Authority.

Conclusion: The impugned assessment orders were set aside and the matters were remanded for fresh assessment after granting due opportunity of hearing, subject to deposit of 20% of the disputed tax.

Final Conclusion: The petitioners obtained conditional relief by way of remand for fresh adjudication, while the assessment proceedings were not finally affirmed and the merits were left open before the Assessing Authorities.

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