In a significant ruling dated 16 August 2025 in case of M/s Gajraj Singh vs Union of India & Others , the Allahabad High Court has clarified that service of notice under the Central Goods and Services Tax (CGST) Act, 2017, through the registered email address of the taxpayer is legally valid and sufficient for computing the limitation period. The decision settles an important issue frequently raised by assessees who contest proceedings on the ground of non-receipt of email communications. By affirming that electronic service through the registered email constitutes deemed service under Section 169(1)(d), the Court reinforced the principle that taxpayers bear the responsibility to monitor their registered communication channels under GST law.
1. Background of the Case
- The dispute revolved around whether a notice served via email on the registered email address of the assessee could be treated as a valid service for the purpose of calculating limitation periods under the Central Goods and Services Tax (CGST) Act, 2017.
- The assessee challenged the proceedings on the ground that proper service was not effected and hence the proceedings were barred by limitation.
2. Relevant Law
- Section 169(1)(d) of the CGST Act, 2017: Provides that service of notice may be effected by sending a communication to the registered email address of the taxpayer.
- Section 75(10): Prescribes the limitation for issuance of adjudication orders under GST.
- Principle of Natural Justice: Service of notice is crucial to provide the taxpayer an opportunity of being heard.
3. Arguments
Petitioner (Assessee)
- Claimed that mere email communication is not proper service.
- Asserted that since the email was not read/opened, the limitation period could not be counted from that date.
- Contended that non-receipt deprived them of a fair opportunity to respond.
Respondent (Revenue/Department)
- Argued that registered email service is expressly recognized under Section 169(1)(d).
- Once the notice is sent to the registered email ID, service is deemed to have been effected.
- Therefore, the limitation period is validly calculated from the date of email delivery.
4. High Court’s Findings
- The Court held that:
- Statutory Recognition: The CGST Act explicitly provides that service of notice on the registered email address is a valid mode of service.
- Deemed Service: Once notice is sent to the registered email, it is deemed served, irrespective of whether the assessee actually read or acknowledged it.
- Limitation Period: For the purpose of limitation, the date of email service will be taken as the relevant date.
- Assessee’s Responsibility: Taxpayers are obligated to regularly check their registered email and GST portal, as they themselves furnished the email during registration.
5. Ratio Decidendi
👉 Service of notice on the registered email ID under Section 169(1)(d) of the CGST Act is sufficient for calculating the limitation period. The assessee cannot avoid proceedings by claiming non-receipt or non-reading of the email.
6. Significance of the Ruling
- Clarifies the validity of electronic communication under GST law.
- Strengthens the department’s ability to defend proceedings against limitation challenges.
- Imposes greater responsibility on taxpayers to monitor their registered communication channels.
- Reduces procedural disputes and promotes digital governance under GST.
✅ Key Takeaway: Under the CGST Act, service by email to the registered ID is legally sufficient. The clock for limitation starts ticking from the date of such email, not from when the assessee actually checks or reads it.