Facts of the Case
The
petitioner, M/s Trans India Logistics, challenged the show cause notice dated
29 September 2023 and the consequential adjudication order dated 23 December
2023 pertaining to Financial Year 2017–18 passed by Sales Tax Officer/AVATO,
Ward-60, Delhi. The petitioner also challenged Notification Nos. 09/2023 and
56/2023 issued under Section 168A of the CGST Act and corresponding State Tax
notifications extending limitation. The petitioner asserted that the SCN was
uploaded only under the “Additional Notices” tab on the GST portal and was not
brought to its knowledge, resulting in no reply being filed and the order being
passed ex parte. The broader challenge to the notifications was already pending
before the Supreme Court in SLP No. 4240/2025, with divergent views across High
Courts.
Issues Involved
Whether
the ex parte adjudication order deserved to be set aside due to lack of
effective service/opportunity where the SCN was uploaded only under the
“Additional Notices” tab, whether the petitioner should be granted portal
access, time to reply and a personal hearing, and whether adjudication should
proceed subject to the outcome of the Supreme Court’s decision on the validity
of Section 168A notifications.
Petitioner’s Arguments
The
petitioner submitted that it had no effective notice of the SCN as it was
uploaded only on the “Additional Notices” tab, resulting in denial of
opportunity to respond and be heard. It sought remand with directions for
portal access, filing of reply and personal hearing. The petitioner also
pressed challenges to the impugned notifications, while seeking interim relief
on facts.
Respondent’s Arguments
The
Revenue relied on the impugned order and the notifications, submitting that the
issue of validity of the notifications was pending before the Supreme Court and
that appropriate directions could be issued consistent with judicial
discipline.
Court Order / Findings
The
Delhi High Court noted the pendency of the validity challenge to the impugned
notifications before the Supreme Court in SLP No. 4240/2025 and the approach
adopted by this Court in similar matters. On facts, the Court accepted that the
SCN issued on 29 September 2023 was uploaded on the “Additional Notices” tab
and was not effectively brought to the petitioner’s notice, leading to an ex
parte order. Following earlier decisions in analogous circumstances, the Court
held that the petitioner deserved an opportunity to file a reply and be heard
on merits. Accordingly, the impugned adjudication order was set aside, portal
access was directed to be enabled, timelines were fixed for filing reply and
personal hearing, and it was clarified that any fresh order would remain
subject to the outcome of the Supreme Court’s decision on the validity of the
impugned notifications.
Important Clarification
The
Court clarified that while granting factual relief by remanding the matter to
ensure compliance with principles of natural justice, it kept the question of
validity of the impugned Section 168A notifications open, making any
adjudication subject to the final decision of the Supreme Court in SLP No.
4240/2025 and the connected proceedings pending before this Court.
Final Outcome
The
writ petition was disposed of. The impugned adjudication order dated 23
December 2023 was set aside. The petitioner was granted time until 31
August 2025 to file a reply to the SCN after restoration of GST
portal access, a personal hearing was directed with communication by email and
mobile, and the adjudicating authority was directed to pass a fresh order in
accordance with law, subject to the outcome of the Supreme Court proceedings on
the impugned notifications.
Link to Download Order https://www.mytaxexpert.co.in/uploads/1769497536_MSTRANSINDIALOGISTICSVsGSTOWARD60ANR..pdf
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