Facts of the Case:

In this case, the petitioner challenged the validity of the show cause notice dated 22.10.2020, the Order-in-Original dated 29.03.2024, and the appellate order dated 15.10.2025 on the ground that all proceedings were conducted at an incorrect address. The petitioner had duly intimated the change of address on 27.06.2017, and the updated address was also reflected in the GST Registration Certificate (Form GST REG-06). Despite this, the department issued the show cause notice and passed subsequent adjudication and appellate orders at the old address.

Consequently, the petitioner did not receive any notice or order and was deprived of the opportunity to respond or defend the case. The petitioner only became aware of the proceedings at a later stage and raised this issue before the appellate authority, which failed to consider the same. The department admitted that due to handling a large number of assessees, the notices were inadvertently sent to the old address but argued that the orders need not be set aside.

Issue:

Whether proceedings initiated and concluded by serving notices and orders at an incorrect/old address, despite prior intimation of change of address by the assessee are valid in law, or whether such action violates principles of natural justice.

Held that:

The Court held that the entire proceedings were vitiated due to violation of principles of natural justice. It was established that the petitioner had duly informed the department about the change of address and that the updated address was available on record. Despite this, all communications, including the show cause notice, adjudication order, and appellate order, were sent to the old address, resulting in denial of a fair opportunity to the petitioner to present its case. The appellate authority also failed to address this fundamental contention.

Accordingly, the Court quashed and set aside the impugned show cause notice and consequential orders, and remanded the matter back to the authorities for fresh adjudication in accordance with law, with a direction to complete the proceedings within twelve weeks.

Case Name: Sachde Roadlines v. Union of India dated 26.02.2026

To read the complete judgement 2026 Taxo.onilne 767