Rajasthan High Court: Communication of Assessment Orders through Email – Section 107, GST Act

The Rajasthan High Court addressed a petition challenging the Appellate Authority’s rejection of an appeal filed under Section 107(1) of the Rajasthan GST Act, 2017. The core issue was when the “communication” of an assessment order occurs for limitation purposes—specifically, how delay in accessing the portal due to wrong email/mobile credentials should be treated. The petitioner’s GST registration had been done using a consultant’s email and mobile number. When their relationship soured, the consultant refused to share credentials, so the petitioner requested updates. Meanwhile, the Assessing Officer passed an assessment order and attached her bank account. The order was also uploaded on the common portal. The appellate authority dismissed her appeal due to delay, counting from the upload date. The petitioner contested that communication should be counted only when she had actual access: either when her credentials were updated or when she got notice.