Complex GST Portal Architecture Cannot Deprive Taxpayers of Natural Justice: Madhya Pradesh HC

In a significant relief for taxpayers struggling with digital compliance, the Madhya Pradesh High Court has ruled that the failure to respond to a show-cause notice due to its placement under 'Additional Notices' on the GST portal constitutes a violation of natural justice. The bench, comprising Justice Subodh Abhyankar and Justice Jai Kumar Pillai, observed that the complex architecture of the web portal often leads to notices going unnoticed, thereby depriving parties of a fair opportunity to contest tax demands.

While hearing a challenge against a tax demand for the period 2022-23, the Court emphasized that procedural technicalities in digital communication should not override the fundamental right to be heard. The petitioner had approached the Court under Article 226 of the Constitution of India, 1950, challenging orders passed under Section 73 and 107 of the Central Goods and Services Tax Act, 2017.

The Rationale on Procedural Fairness and Portal Architecture

The Court, in its reasoning, observed: "The problem has arisen on account of the complex architecture of the web portal. It has been designed to facilitate easy access of informations. It has however resulted in the petitioner failing to notice the notice that was issued to the petitioner prior to the impugned order... It went unnoticed by the petitioner, as a result of which, the impugned orders have been passed."

The Court relied heavily on the precedent set in Singh Construction and Co. Vs. The State of M.P. and others ( "WP No.11483/2025": 2025 CaseBase(MP) 54462), which dealt with identical circumstances where notices were uploaded under the "Additional Notices and Orders" tab rather than the primary "View Notices" tab. By applying the same logic, the Court found that the petitioner deserved an opportunity to respond to the merits of the case.

Judicial Precedents on Digital Service of Notice

The judgment referred to various decisions across High Courts, including East Coast Constructions and Industries Ltd. v. Assistant Commissioner (ST) ( "[2023] 157 taxmann.com 66": 2023 CaseBase(MAD) 44106), Sabari Infra (P.) Ltd. v. Asstt. Commissioner (ST), and Murugesan Jayalakshmi v. State Tax Officer, which highlighted the technical discrepancy in the GST portal's user interface. It was noted that while the portal has recently been redesigned to merge these tabs, many orders passed during the transition period suffered from this lack of visibility. The Court also took note of the Delhi High Court's findings in Umang Realtech (P.) Ltd v. Union of India and Anhad Impex and another Vs. Assistance Commissioner regarding the insufficiency of service when notices are buried in sub-menus.

Court Directions

The Court has the following directions:

"The impugned order dated 10.03.2025 is hereby set aside and the present petition is also disposed of by holding that the directions issued in Writ Petition No. 11483/2025 [Singh Construction and Co. Vs. The State of M.P. & ors.] will apply mutatis mutandis to the present case also... Respondents shall open the portal to enable the Petitioner to file a response to the said Show Cause Notices Form GST DRC-01 which shall be filed within a period of two weeks. Thereafter, the Proper Officer shall re-adjudicate the Show Cause Notices after giving an opportunity of personal hearing and shall pass fresh speaking orders in accordance with law."

Background:

The dispute arose when the tax authorities raised a demand against Maple Overseas Trade Private Limited for the tax period 2022-23. The petitioner contended that they were entirely unaware of the proceedings because the Show Cause Notice was uploaded under the "Additional Notices and Orders" category in the "User Services" menu, rather than being communicated through standard modes or the primary notice tab.

Due to this lack of awareness, the petitioner could not file a reply or participate in the adjudication process, leading to an adverse order. The State counsel did not dispute that the legal issue regarding the portal's layout had been addressed in favor of taxpayers in previous rulings. Consequently, the High Court set aside the demand and remanded the matter for fresh adjudication, ensuring the petitioner's right to a personal hearing was preserved.

Case Details:
Case No.: WRIT PETITION No. 15868 of 2026
NeutralCitation: 2026:MPHC-IND:16521
Case Title: MAPLE OVERSEAS TRADE PRIVATE LIMITED THROUGH ITS DIRECTOR PAWAN GARG Versus THE STATE OF MADHYA PRADESH
Appearances:
For the Petitioner(s): Shri Arpit Singh - Advocate
For the Respondent(s): Shri Shreya Raj Saxena, Dy.A.G.

Source: 2026 CaseBase(MP) 61