Natural justice in portal notices required merits hearing after explained delay and prior statutory pre-deposit.

Uploading a show-cause notice only under an incorrect portal tab prevented an effective response and violated principles of natural justice. The material discrepancy between the financial year in the appellate order and that in recovery and garnishee proceedings, together with the explained delay in filing the statutory appeal, required merits consideration. The note states that the appellate dismissal on limitation was quashed and the appeal was to be entertained and decided on merits; since the required pre-deposit had already been made, no further deposit was required for an expedited hearing.

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Issues: Whether dismissal of the statutory appeal as time-barred was sustainable where the show-cause notice was uploaded under an incorrect portal tab and the delay was explained.

Analysis: Uploading the show-cause notice only under the 'Additional notice and orders' tab prevented an effective response and resulted in a violation of principles of natural justice. The discrepancy between the financial year covered by the appellate order and that stated in the recovery and garnishee proceedings was material. The explanation for delayed filing of the appeal was sufficient and required consideration while adjudicating the appeal on merits. As the required pre-deposit had already been made, no additional deposit was necessary for expeditious hearing.

Conclusion: The appellate order dismissing the appeal on limitation was quashed, and the appeal was directed to be entertained and decided on merits in accordance with law.

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