GST portal notice accessibility failure invalidated ex parte assessment and appellate order, permitting fresh adjudication through proper notice.

GST notices and orders were required to be accessible under the designated "Notices/Orders" tab, while they were instead displayed under a separate "Additional Notices/Orders" tab. The portal manual and FAQs supported the expectation that the designated tab would contain such communications. As the taxpayer's non-participation resulted from a bona fide belief that no notice or assessment order had been issued, the ex parte assessment and consequential appellate order were unsustainable. Fresh adjudication may be initiated through a fresh notice issued within the prescribed period.

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Issues: Whether an ex parte GST assessment and the consequential appellate order could stand where statutory notices and orders were made available only under the "Additional Notices/Orders" tab of the GST portal rather than the designated "Notices/Orders" tab.

Analysis: The GST portal manual and FAQs indicated that notices should be available under the "Notices/Orders" tab. The Revenue admitted that notices and orders issued by tax officers were displayed under the separate "Additional Notices/Orders" tab and that the portal issue was subsequently resolved. The petitioner's failure to participate in the adjudication was therefore attributable to a bona fide belief that no notice or assessment order had been issued.

Conclusion: The ex parte assessment and appellate order were unsustainable and were set aside in favour of the assessee; the Revenue may initiate fresh adjudication by issuing a fresh notice within the prescribed period.

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