Common portal service of GST notices may not establish effective notice, permitting writ relief against limitation dismissal.

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....Service of a GST show-cause notice solely through upload on the Common Portal may be inadequate where receipt is unacknowledged, no reply is filed, and the taxpayer lacks effective knowledge of the proceedings. Although the statutory limitation period binds the appellate authority, writ jurisdiction may address delay caused by circumstances beyond the taxpayer's control where refusing merits adjudication would cause grave injury or prejudice. In the stated circumstances, delay in filing the GST appeal against an input tax credit demand was condoned, the limitation-based dismissal was set aside, and the appellate authority was directed to decide the fresh appeal on merits without raising limitation.....