The Gujarat High Court has held that service of notices and orders at an outdated address—despite the taxpayer having duly updated its address in GST records—amounts to a violation of principles of natural justice, rendering the entire proceedings unsustainable.
The bench of Justice A.S. Supehia and Justice Pranav Trivedi has observed that the petitioner had been effectively denied an opportunity to defend its case. The consistent failure of the authorities to serve notices and orders at the correct address—despite having official records reflecting the updated details—resulted in a clear breach of natural justice.
The case arose from a writ petition filed by M/s Sachde Roadlines, where the petitioner challenged the validity of the show cause notice, adjudication order, and appellate order on the ground that none of these were ever received. The petitioner had, as early as 27.06.2017, formally intimated the change in address to the department, and the updated address was duly reflected in the GST Registration Certificate (Form GST REG-06).
Despite this, the department proceeded to issue a demand-cum show cause notice dated 22.10.2025 under Section 174(2)(d) of the Central Goods and Services Tax Act, 2017 to the petitioner’s old address. The petitioner contended that this notice was never received. Subsequently, all further proceedings—including adjudication and passing of the Order-in-Original dated 29.03.2024—were also conducted and communicated at the same outdated address.
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The petitioner only became aware of the proceedings at a later stage and thereafter filed an appeal. Notably, while filing the appeal in Form ST-4, the petitioner once again furnished the correct and updated address. However, even at the appellate stage, the authority failed to take note of this crucial aspect and proceeded to pass the order in appeal dated 15.10.2025, which too was issued and communicated at the old address.
A key grievance raised before the High Court was that the appellate authority had completely ignored the specific contention regarding non-service of notices and orders. Despite being clearly informed that the petitioner had not received any communication due to incorrect service, the appellate authority failed to examine or address this issue while deciding the appeal.
The Court emphasized that proper service of notice is a foundational requirement for any adjudication. Where the assessee is not put to notice due to service at an incorrect address, the entire proceedings stand vitiated, irrespective of the merits of the case.
The High Court set aside the show cause notice, the Order-in-Original, and the appellate order, holding that the proceedings were conducted in violation of natural justice. The matter has been remanded back to the appropriate authority for fresh adjudication in accordance with law, with all rights and contentions of both sides kept open.
Case Details
Case Title: M/S Sachde Roadlines Versus UOI
Citation: JURISHOUR-917-HC-2026(GUJ)
Case No.: R/Special Civil Application No. 2515 Of 2026
Date: 26/02/2026
Counsel For Appellant: Abhay Y Desai
Counsel For Respondent: Neel P Lakhani
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