Supreme Court : Upholds High Court’s view that emails to GST Practitioner constitute valid service

Supreme Court dismisses Assessee’s SLP challenging the Delhi High Court’s judgement which had upheld the validity of service of personal hearing notices issued under the CGST Act, holding that service of notice on the registered e-mail address reflecting the GST Practitioner/Chartered Accountant’s email is sufficient communication under section 169(1)(c); Earlier, Delhi High Court had found no violation of natural justice and held that the Assessee had concealed the fact that notices were, in fact, received on the registered GST email appearing on the portal; Additionally, High Court also affirmed the legality of consolidated show cause notices covering multiple Financial years, observing that such consolidation may become necessary to demonstrate the pattern of alleged tax evasion; Declining to interfere,  Supreme Court finds “…no good ground and reason to interfere with the impugned judgment/order passed by the High Court..” leaving the High Court’s dismissal and the Rs 50,000 cost intact. [In favour of revenue] – [Mathur Polymers v. Union of India & Ors. [TS-919-SC-2025-GST] – Date of Judgement : 07.11.2025 (SC)]

PRECAUTIONS FOR PROFESSIONALS

  1. Ensure the GST portal profile contains updated and active email IDs of the assessee and the authorised representative.

  2. Regularly monitor email inbox, spam folder, and GST portal notifications to avoid missing notices.

  3. Maintain internal tracking systems for notices received on practitioner email IDs.

  4. Communicate all notices received to clients promptly with documented proof.

  5. Advise clients that service on the consultant’s registered email is legally valid and binding.

  6. Avoid relying solely on physical notices; treat email communication as final service for statutory timelines.

  7. In case of multiple-year consolidated SCNs, prepare defence considering overall transaction patterns.

  8. Maintain comprehensive year-wise documentation to handle consolidated allegations effectively.

  9. Avoid contesting service issues without verifying email records; concealment may lead to costs and judicial criticism.

  10. Educate clients on the risk of non-compliance due to missed email notices, given this Supreme Court affirmation.