The Court said it was 'shocked and appalled' that the system permitted issuance of three separate notices with different hearing dates within an interval of approximately two minutes.
The Gujarat High Court has taken serious exception to the generation of three separate notices for personal hearing — bearing three different notice numbers, different dates, and different times — all digitally signed on the same date within an interval of roughly two minutes. The Court directed the Chief Commissioner of State Tax to file a report explaining the portal's functioning and warned that exemplary costs would be imposed if the explanation was found unsatisfactory [Mustufamiya Hussainmiya Shaikh, Proprietor of M/s Mustufa Sales Agency v. State of Gujarat & Ors.].
The bench of Justices A.S. Supehia and Vaibhavi D. Nanavati was hearing a writ petition challenging an appellate order. When the matter came up for hearing, the respondent's counsel tendered three notices — all dated 16.04.2026 — that had been issued by the Deputy Commissioner of State Tax (Appeals). Each notice bore a different number and fixed a different date for personal hearing: 18.04.2026, 21.04.2026, and 24.04.2026. The digital signatures on the three notices were applied within a span of approximately two minutes.
The Court observed that this was "a very serious lacuna which would permit the concerned authority to manipulate the system by generating three notices on the same date, digitally signed within an interval of approximately two minutes."
The bench directed the Chief Commissioner of State Tax, as the highest authority, to file a report on the functioning of the portal and the process that allows such simultaneous generation of notices. It further directed the appellate authority to pass a fresh appellate order and warned that strictures would follow if the report was not filed by the next date of hearing.
2026-juristway.com-3077-HC(Gujarat)-GST
