Rajasthan HC: GST Portal Upload Alone Does Not Start Appeal Deadline Without Proper Service

The Rajasthan High Court held that mere upload of a GST order on the common portal does not trigger the period of limitation for filing an appeal unless the taxpayer has been served with proper notice, and condoned a 645-day delay in filing an appeal on this basis. The court clarified that procedural safeguards requiring actual service of GST orders on taxpayers remain mandatory, and that electronic upload alone on the GSTN portal cannot substitute for legally cognizable notice. This ruling is crucial because it protects taxpayers from losing appellate rights due to portal-based orders they were unaware of, and establishes a high bar for what constitutes valid commencement of appeal deadlines. The decision reinforces that GST authorities cannot rely on unilateral portal uploads to serve assessment orders, and must follow proper service procedures. Businesses should ensure they receive and acknowledge formal notice of all GST orders, request confirmation of service, and not assume that portal visibility equals valid legal notice for limitation purposes.