Service of tax notices via portal may not satisfy natural justice unless alternative communication ensures actual notice.
Portal-only publication of tax notices does not by itself satisfy the sequential service requirement under Section 169; primary modes such as personal delivery, registered post or electronic communication must be attempted and portal upload is supplementary. Authorities and taxpayers must ensure notices appear in the designated portal section and that contact details and practitioner authorisations enable actual receipt to preserve the taxpayer's right to an adequate opportunity to respond. (AI Summary)