Atlantis Intelligence Ltd. Vs Union of India And 2 Others (Allahabad High Court)
That in the case of Atlantis Intelligence Ltd. v/s Union of India and 2 Others (Writ Tax No. 3608 of 2025) The Allahabad High Court has clarified that under Section 169 of the Central Goods and Services Tax (CGST) Act, 2017, service of an order or notice on the registered email of a taxpayer is sufficient for calculating the limitation period. The division bench ruled that insisting on multiple modes of service would render the provision meaningless and defeat its legislative intent.
The Court held that once service is made through the registered email, limitation begins from that date itself. A taxpayer cannot argue that other prescribed modes of service under clauses (a) to (f) of Section 169(1) were not followed. The provision allows service by any one of the listed methods, and requiring more than one would be “absurd.”
The Court further examined Section 107 of the CGST Act, which provides for an appeal against an order within three months, extendable by one month if sufficient cause is shown. It emphasized that limitation is a statutory mandate, and courts cannot extend it beyond what is prescribed.
