1.1 Brief of the Case

1.2 Background of the case

• Department issued an ex-parte GST demand notice under Section 73 via the GST portal’s “Additional Notices” tab—Rajvijay & Co. wasn’t aware of this until after proceedings.
• Without response opportunity, the authority proceeded and even attached the petitioner’s bank account. The petitioner only learned upon seeing a deduction.

1.3 Action taken by Departments

• Section 73, CGST Act – issuance of show-cause notices for tax demand
• Section 169, CGST Act – modes of valid service of notices, especially requiring an opportunity for the assessee
• Audi alteram partem – principle of natural justice mandating hearing before action

1.4 Petitioner’s Arguments

•  Notice was not properly communicated—deposited only in an obscure portal tab, without any physical or alternate mode.
• As they didn’t receive it, they had no opportunity to respond, violating natural justice.
• The bank’s attachment and demand based on such unheard proceedings was invalid and unreasonable.

1.6 Court’s Findings and Analysis

• Recognized e‑service is permissible, but it must be effective, not just technical uploading.
• Noted that when portal notices go unseen and department fails to use additional statutory modes, service cannot be deemed
• Emphasized the requirement to uphold natural justice—taxpayers must have a genuine opportunity to respond.

1.7 Court’s Decision

• Quashed the ex‑parte GST demand issued without fair notice.
• Set aside the attachment of bank accounts configured under that demand.
• Remanded back—directing the authority to issue a fresh notice, provide a hearing, and pass a final order.
• Condition: petitioner to deposit 25% of disputed demand before new hearing

1.8 Significance of the Judgment

• Reinforces natural justice: mere upload on portal isn't enough if taxpayer remains unaware.
• Clarifies that authorities must use alternate modes if portal service is inadequate.
• Introduces a balanced mechanism: taxpayers get relief but must make partial deposit (25%) to rebuild trust and financial collateral.
• Important procedural precedent—portal-only notices may no longer support ex-parte actions.

1.9 Conclusion

The Madras High Court struck a strong procedural tone, asserting that GST authorities cannot rush through ex‑parte proceedings without genuine notification and hearing. The requirement to deposit only 25% for reassessment chances offers balanced taxpayer protection, reinforcing the principles of natural justice under GST law.