Valid GST service requires prescribed delivery; portal-only uploading cannot support ex parte adjudication or start appeal limitation.

Uploading a show-cause notice or order-in-original only in the GST Common Portal's 'View Additional Notices and Orders' tab does not constitute valid service under the CGST Act and Rules. The retrospective amendment on portal functions does not permit the portal to replace prescribed formal service, and electronic communication cannot validate mere uploading where the notice or order was not duly served. Portal-only uploading may not be challenged if the taxpayer acknowledged receipt and replied; however, where it resulted in ex parte adjudication, proceedings require restoration to the show-cause-notice stage. For contested orders, the appeal limitation period does not begin from portal uploading alone.

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Issues: Whether uploading a show-cause notice or order-in-original in the 'View Additional Notices and Orders' tab on the GST Common Portal constitutes valid service under the Central Goods and Services Tax Act, 2017.

Analysis: The prior rulings governing the issue were applied. The retrospective amendment concerning functions capable of being performed on the Common Portal does not authorise the portal to substitute formal service of a show-cause notice or order. The Central Goods and Services Tax Rules, 2017 do not provide for service of such notice or order merely through the Common Portal; electronic communication under the Rules does not validate portal uploading where the document itself is not duly served. Portal-only uploading may not be challenged where the assessee acknowledged receipt or contested the proceedings by filing a reply; however, an ex parte adjudication following portal-only uploading requires restoration to the show-cause-notice stage, while limitation for an appeal against a contested order does not commence from such uploading.

Conclusion: Uploading a show-cause notice or order-in-original only on the Common Portal does not by itself amount to valid service. The writ petition was governed by the relief and consequences laid down in the prior rulings.

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