Disputed service of tax notices requires appellate factual review, absent an apparent or undisputed breach of natural justice.

Alleged non-service of show-cause and hearing notices did not justify bypassing the statutory appellate remedy where service was disputed. The notes state that the taxpayer denied receipt, while Revenue relied on dispatch to the registered address and portal upload under the prescribed service provision. Questions concerning the sufficiency of service, the effect of a rejected registration-cancellation application, and the need for further service modes required factual appraisal by the appellate authority. As no apparent or undisputed breach of natural justice was established, extraordinary writ jurisdiction was not warranted and the statutory appeal remained the appropriate remedy.

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Issues: Whether the alleged non-service of the show-cause notice and hearing notices constituted an exceptional breach of natural justice justifying writ jurisdiction despite the statutory appellate remedy.

Analysis: The statutory appeal under Section 107 provides the ordinary mechanism for challenging the original adjudication order. The asserted lack of service was disputed: the petitioner denied receipt, whereas the Revenue relied on dispatch to the registered address and portal upload under Section 169. The validity and sufficiency of service, the effect of the rejected registration-cancellation application, and whether additional modes of service were required involved disputed factual issues requiring appraisal by the appellate authority. No apparent or undisputed breach of natural justice was established to warrant departure from the alternative-remedy rule.

Conclusion: The alleged violation of natural justice did not justify exercise of extraordinary writ jurisdiction; the petitioner must pursue the statutory appellate remedy.

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