Physical service of show cause notice required after cancellation of registration; portal-only notice breached natural justice and hearing rights.

Physical service of the show cause notice was required where the taxpayer's registration had already been cancelled before notice issuance, and portal-only service was insufficient. Because no notice or supporting documents were served physically, the taxpayer was denied an effective opportunity to file a reply and raise objections, amounting to a substantial breach of natural justice. The right to be heard under Section 75(4) was treated as infringed, and the adjudication order was set aside with a direction for fresh adjudication after physical service of notice and documents.

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Issues: Whether the adjudication order was vitiated for want of physical service of the show cause notice after cancellation of registration, resulting in denial of opportunity of reply and hearing.

Analysis: The registration against which the proceedings were initiated had already been cancelled before issuance of the notice. In such a situation, service of notice only through the common portal was held insufficient, and physical service was required. Since no physical notice was served and the petitioner was thereby prevented from filing a reply or objecting to the notice, there was a substantial violation of the principles of natural justice. The statutory right to be heard under Section 75(4) was also treated as infringed.

Conclusion: The adjudication order was set aside and the matter was remitted for fresh adjudication after service of notice and documents through physical mode.

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