Service of a show cause notice through the GST common portal was...

Service of a show cause notice through the GST common portal was treated as valid where the taxpayers later admitted the notice was available there, so the non-service challenge failed and the best judgment assessment stood. The limitation objection also failed: the court accepted that lesser tax payment despite knowledge of the applicable rate amounted to suppression, attracting the extended period, and relied on the notification extending the annual return due date to hold that the order was passed within time. The writ petition was dismissed and the order-in-original upheld.