The Allahabad High Court has reiterated that the GST common portal must clearly and separately display the date of a notice or order and the date on which it was uploaded, stressing that such visibility is crucial to reducing disputes over appeal limitation.
A Division Bench of Justice Saumitra Dayal Singh and Justice Swarupama Chaturvedi observed that the changes proposed by the Goods and Services Tax Network (GSTN) might still fail to address the central concern raised in the proceedings. The Court also expressed dissatisfaction with GSTN seeking another six months to introduce changes despite having received adequate opportunities.
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The Court fixed the next hearing for November 16, 2026, and extended the interim order operating in this case and connected matters until further orders.
The Bench recalled that its orders dated August 12, September 7 and September 28, 2026, had identified the need for changes to the GST common portal.
Specifically, the September 28 order had suggested that the date of an order and the date of its uploading should be easily and separately visible to taxpayers on their dashboard. The Court had referred to the display of orders on the High Court website as an illustration that could be replicated.
At the previous hearing, GSTN had assured the Court that efforts were being made to incorporate the changes. Additional time had been granted, and the matter was being considered again after more than a month.
GSTN’s counsel placed written instructions dated November 1, 2026, before the Court, outlining proposed changes to the Back Office and Front Office portals.
For the Back Office portal, GSTN proposed introducing two additional fields to capture the notice or order number and the date appearing on the signed copy. These particulars would also appear in the corresponding generated PDFs. The existing system-generated reference number and issuance date would remain unchanged.
For the taxpayer-facing Front Office portal, the “View Notices and Orders” page would be enhanced to display the notice or order number and date recorded in the signed copy.
GSTN also proposed displaying details of email and SMS notifications sent to taxpayers, including the recipient email address or mobile number and the date and time of communication. Where information was unavailable, the relevant field would display “NA”.
The Bench clarified that it was not disapproving the individual changes proposed by GSTN. However, it considered that these changes might still fail to address the principal problem.
The Court required the concerned GSTN authorities to study its earlier orders again, particularly the illustration showing the order date and upload date in separate columns on the page listing orders passed in a proceeding.
The emphasis was on making both dates immediately and distinctly visible to taxpayers. The Court said that the same ease of visibility was required for notices as well as orders.
Accordingly, merely adding particulars from the signed copy would not necessarily meet the Court’s concern. The portal needed to make the distinction between the date of the order and its upload date readily apparent.
The Court explained that disputes would continue unless the necessary changes were made. It referred to cases involving allegations that orders had not been uploaded on the date they were passed, as well as orders appearing to have been passed much later than the last hearing date communicated to the assessee.
The Bench also stressed that officers needed to be enabled to upload orders within a reasonable time after passing them. Addressing this aspect was necessary to adequately resolve the problem.
Clear visibility of both dates would allow taxpayers to identify the interval between an order being passed and its uploading on the portal.
Explaining the relevance to appeal limitation, the Court observed that once both dates were easily visible, an assessee would be able to seek exclusion of the time taken by the officer between passing the order and uploading it.
The Bench considered these measures necessary to reduce unnecessary litigation and help ensure that appeals were filed within the prescribed limitation period, particularly where the limitation requirements were strict.
The order does not automatically extend appeal deadlines or exclude every uploading delay. Its observation concerns enabling taxpayers to identify the relevant interval and seek its exclusion for limitation purposes.
The Bench expressed dissatisfaction with GSTN seeking another six months, noting that adequate opportunities had already been provided. It observed that the lengthy period requested might not be conducive to public interest.
On a query from the Court, GSTN’s counsel stated that the learned Additional Solicitor General had sought further time to obtain instructions.
The Court consequently listed the matter for November 16, 2026, while continuing the earlier interim protection. The order neither records acceptance of the proposed six-month implementation period nor finally disposes of the petition.
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