Vallabbh Steels Limited vs. State Of Punjab

Held

The High Court held that the question of whether uploading a notice and an order-in-original in the 'View Additional Notices and Orders' tab on the common GST portal constitutes proper service under Section 169 read with Section 146 of the Goods and Services Tax Act, 2017, is no longer res integra. The Court found that this issue has been conclusively decided by its own previous judgments in CWP-27139-2025, Luxmi Traders v. Union Territory of Chandigarh and Others, and further clarified in CWP-15601-2026, The Amar Cooperative LC Society Ltd. v. State of Haryana and Others. Consequently, the instant writ petition was disposed of in the same terms as these prior judgments. The specific findings and reasoning from those prior judgments, which would form the ratio decidendi for this case, are not detailed in the provided text, but the operative direction is to dispose of the petition based on those precedents.

Facts

The petitioner, Vallabh Steels Limited, filed a writ petition before the Punjab and Haryana High Court challenging the validity of service of a notice and an order-in-original. The petitioner contended that uploading these documents in the 'View Additional Notices and Orders' tab on the common GST portal (www.gst.gov.in) does not constitute proper service. The dispute centers on whether this method of communication satisfies the requirements of Section 169 read with Section 146 of the Goods and Services Tax Act, 2017. The tax period and the specific authority issuing the notice and order are not explicitly detailed in the provided text, nor is the amount in dispute.

Key Issues

1. Whether uploading a notice and an order-in-original in the 'View Additional Notices and Orders' tab on the common GST portal amounts to proper service on the petitioner, in light of Section 169 read with Section 146 of the Goods and Services Tax Act, 2017? The petitioner argued that such an upload does not constitute proper service. The revenue (State of Punjab and Another) did not present any arguments as the matter was considered concluded by previous judgments. The petitioner relied on the principle that service must be effected in a manner that ensures actual notice or a reasonable chance of notice, which they contended was not met by a mere upload on a portal without further notification. The revenue's position was not recorded in the judgment.