Electronic GST notice service remains valid, while unavailed statutory remedies generally restrict writ challenges to demands and registration cancellation.

GST portal upload is described as a statutorily recognised mode of serving show-cause notices, so absence of physical service does not by itself establish breach of natural justice where the recipient does not respond. The notes further address Article 226 writ jurisdiction, stating that challenges to GST demands and registration cancellation should ordinarily proceed through available statutory revival and appellate remedies. Where those remedies remain unavailed, grounds concerning notice, demand, or cancellation may be raised before the prescribed statutory forum rather than in writ proceedings.

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Issues: (i) Whether show-cause notices uploaded on the GST portal, without physical service, constituted valid service and whether the subsequent proceedings suffered from violation of principles of natural justice; (ii) Whether writ jurisdiction under Article 226 should be exercised against GST demand and cancellation of registration when the petitioner failed to respond to notices and did not avail the statutory remedies of revival and appeal.

Issue (i): Whether show-cause notices uploaded on the GST portal, without physical service, constituted valid service and whether the subsequent proceedings suffered from violation of principles of natural justice.

Analysis: The notices were admittedly uploaded on the GST portal. Under the GST statutory scheme, uploading on the portal is recognised as a valid mode of service. The contention that physical service was mandatory was not accepted. Since the petitioner did not respond despite valid service, the challenge based on lack of notice and breach of natural justice did not survive.

Conclusion: Service through the GST portal was valid, and the plea of violation of principles of natural justice was rejected; this issue was decided against the assessee.

Issue (ii): Whether writ jurisdiction under Article 226 should be exercised against GST demand and cancellation of registration when the petitioner failed to respond to notices and did not avail the statutory remedies of revival and appeal.

Analysis: The petitioner did not reply to the show-cause notices, did not seek revival after cancellation of registration, and did not file the statutory appeal. The matter involved remedies specifically provided under the GST enactments, including appellate recourse subject to limitation and pre-deposit. Grounds sought to be urged in the writ petition were considered capable of being raised before the statutory forum. In these circumstances, invocation of writ jurisdiction was found unwarranted.

Conclusion: The writ petition was not maintainable in the presence of an efficacious statutory remedy that had not been availed; this issue was decided against the assessee.

Final Conclusion: The GST proceedings, including cancellation of registration, were left to stand, and the petitioner was relegated to the statutory appellate framework rather than obtaining relief in writ jurisdiction.

Ratio Decidendi: Where GST notices are served by a statutorily recognised electronic mode through the portal, absence of physical service does not invalidate the proceedings; and when statutory remedies against demand or cancellation are available but not pursued, writ jurisdiction under Article 226 need not be invoked.

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