Sri Veeranjaneya Pulverisers vs. The Deputy Assistant Commissioner

Held

The Court acknowledged that uploading documents on the portal is sufficient service under Section 169 but noted that lack of alerts often leads to non-compliance with natural justice for taxpayers with inadequate technical abilities. Consequently, the assessment orders were set aside, and the matters were remanded for fresh assessment after due notice, conditional upon the petitioner paying 20% of the disputed tax within six weeks.

Facts

The petitioner challenged assessment orders for multiple periods and subsequent attachment notices, contending that they never received the assessment notices or orders. The department argued that service was properly effected by uploading the documents onto the GST portal as per Section 169(1)(d) of the GST Act.

Key Issues

The key legal issue was whether service of assessment notices and orders solely by uploading them on the GST portal, without any additional alerts, constitutes valid service and adheres to the principles of natural justice.