Physical service of GST notice required after registration cancellation; portal-only service violated hearing rights and natural justice.

Where registration had already been cancelled, service of the adjudication notice only through the Common Portal was held insufficient because the statutory mode under Section 169(1)(a)(b) of the Uttar Pradesh GST Act required physical service. The absence of physical notice substantially deprived the taxpayer of an opportunity to reply or appear, so the hearing safeguard under Section 75(4) was treated as breached and the principles of natural justice were violated. The adjudication order was set aside and the matter was remitted for fresh adjudication after proper physical notice, supply of relied upon documents, and opportunity of hearing.

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Issues: Whether the adjudication order was liable to be set aside for want of physical service of the show cause notice after cancellation of registration, resulting in denial of opportunity to object and be heard.

Analysis: The petitioner's registration had already been cancelled, and in such circumstances service of adjudication notice only through the Common Portal was held insufficient. The notice was required to be served physically in view of the statutory mode of service under Section 169(1)(a)(b) of the Uttar Pradesh Goods and Services Tax Act, 2017. Since no physical notice had been served, the petitioner was found to have been substantially deprived of the opportunity to submit a reply or appear in the proceedings. The right of hearing under Section 75(4) of the Uttar Pradesh Goods and Services Tax Act, 2017 was therefore treated as having been breached, amounting to violation of the principles of natural justice.

Conclusion: The adjudication order was set aside and the matter was remitted for fresh adjudication after proper physical notice, supply of relied upon documents, and grant of opportunity of hearing.

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