Facts of the Case

M/s Narayana Hrudayalaya Limited filed this writ petition against the Excise and Taxation Officer and another, challenging proceedings arising from a notice and order-in-original that had been uploaded only under the “View Additional Notices and Orders” tab of the GST common portal. As in the connected batch of matters before the same Bench, the short question was whether such uploading satisfies Section 169 read with Section 146 of the CGST Act, 2017 — a question already answered in Luxmi Traders v. Union Territory of Chandigarh (CWP-27139-2025), as further clarified in The Amar Cooperative LC Society Ltd. v. State of Haryana (CWP-15601-2026).

Issues Involved

  1. Whether uploading of a notice/order only under the portal's “Additional Notices and Orders” tab amounts to proper service under Section 169 read with Section 146 of the CGST Act, 2017.
  2. The effect of the retrospective validation under Section 115 of the Finance Act, 2022 on this question.

Petitioner's Arguments

  • The controversy was squarely covered by Luxmi Traders, which had already rejected the Revenue's reliance on the Finance Act, 2022 amendment for this purpose.

Respondent's Arguments

  • The Revenue reiterated the contention that Section 115 of the Finance Act, 2022 retrospectively extends all CGST Rules functions, including service of process, to the Common Portal.

Court Order / Findings

  • Reiterating its reasoning in Luxmi Traders (paragraphs 58–60) — that none of the CGST Rules, 2017 designates the Common Portal for the specific purpose of service of SCNs/orders — the Bench declined to take a different view on account of Section 115 of the Finance Act, 2022.
  • The writ petition was disposed of in terms of Luxmi Traders, with a further direction that where 10% statutory pre-deposit had already been made at the time of filing an appeal, the appeal itself would be heard on merits, and any bank-account attachment consequent upon the challenged order would stand revoked.

Important Clarification

  • The Common Portal's role under the CGST Rules, 2017 is confined to functions like registration, return filing, payment and refunds; it is not designated for service of SCNs or orders, so uploading solely under the “Additional Notices and Orders” tab does not satisfy Section 169, irrespective of the retrospective notification validation under Section 115 of the Finance Act, 2022.

Sections Involved

  • Section 169 of the CGST Act, 2017 — modes of service.
  • Section 146 of the CGST Act, 2017 — Common Portal.
  • Section 115 of the Finance Act, 2022 — retrospective validation of the Common Portal notification.

Decision – In Favour of

Assessee, disposed of in terms of the Luxmi Traders framework.

Case Details

High Court of Punjab and Haryana at Chandigarh; CWP-16177-2025 (O&M); Coram: Hon'ble the Acting Chief Justice Ashwani Kumar Mishra and Hon'ble Mr. Justice Rohit Kapoor; Date of Decision: 27.07.2026.

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