[2025:RJ-JP:33032-DB] HIGH COURT OF JUDICATURE FOR RAJASTHAN BENCH AT JAIPUR D.B. Civil Writ Petition No. 11549/2025 1. M/s Lakshya Bricks, 43 Vijay Complex, Scheme No. 2, Alwar-301001 Gstin-08Aaefl6476F1Z3 Through Its Partner Shri Anil Agarwal 2. Anil Agarwal, S/o Shri Prakash Agarwal, Aged About 54 Years, R/o Jawali Bhawan Colony, Station Road, Alwar, Rajasthan-301001 ----Petitioners Versus 1. State Of Rajasthan, Through Joint Secretary (Tax) Finance Department (Tax Division), 1St Floor, Main Building, Gate-2, Government Secretariat, Jaipur, Rajasthan-302005 2. Union Of India, Through The Revenue Secretary, Department Of Revenue, Ministry Of Finance, North Block, New Delhi-110001 3. Joint Commissioner (State Tax), Commercial Taxes Department, Circle-B, Enforcement Wing-I, State Tax- Rajasthan, Jaipur Having Its Office At Room No. 410, 3Rd Floor, Kar Bhawan, Ambedkar Circle, Jaipur-302005 4. Assistant Commissioner (State Tax), Ward I, Circle A, Alwar Address Room No. 120, First Floor, Kar Bhawan, Hkm Nagar, Alwar, Rajasthan. 5. State Tax Officer, Ward I, Circle A, Alwar Address Room No. 120, First Floor, Kar Bhawan, Hkm Nagar, Alwar, Rajasthan. ----Respondents For Petitioner(s) : Ms. Priyansha Gupta, Adv. For Respondent(s) : Mr. C.S. Sinha, Adv. with Mr. Rajat Sharma, Adv. Mr. Yatharth Asopa, Adv. Mr. B. Vyas, AAG with Ms. Niti Jain Bhandari, Adv. HON'BLE MR. JUSTICE SANJEEV PRAKASH SHARMA HON'BLE MR. JUSTICE SANJEET PUROHIT Order 21/08/2025 1. Issue notice to the respondents. [2025:RJ-JP:33032-DB] (2 of 3) [CW-11549/2025] 2. Mr. Bharat Vyas, learned Additional Advocate General, accepts notice on behalf of the respondent Nos.1,3,4 and 5. 3. Mr. C.S. Sinha, accepts notice on behalf of respondent No.2. 4. One of the arguments raised by learned counsel for the petitioners is that service is not provided under Section 169 of the CGST Act. It would have to be uploaded on portal and notices must be sent to the tax payers firstly, through registered E-mail or by registered post. Merely placing the notice on the portal cannot be said to be a sufficient service. 5. In the present case, the petitioners have pointed out that on account of the notices having been only placed on the portal, the petitioners would not know and contest the said notices. Ex-parte orders were passed and on the basis of those ex-parte orders, the bank accounts have been seized which has resulted in the petitioners’ business coming to halt. 6. Learned counsel for the petitioners submits that petitioners have already paid the principal amount of Rs.1,29,584/- while along with interest, the amount comes to Rs. 3,53,778/-. 7. Keeping in view that the amount deposited is more than 10 per cent, we stay further recovery amount and direct the respondents to release the bank accounts of the petitioners for doing further business. The deposition of the amount of Rs.1,29,584/- would be treated as sufficient for entertaining the appeal under Section 107 of the CGST Act. 8. The petitioners would be free to challenge the orders of recovery before the Appellate Authority which will be examined on merits and the speaking order shall be passed after giving an [2025:RJ-JP:33032-DB] (3 of 3) [CW-11549/2025] opportunity of hearing to the petitioners within a period of three months. 9. With the aforesaid observations, the present civil writ petition is disposed of. 10. All pending application(s), if any, stand disposed of. (SANJEET PUROHIT),J (SANJEEV PRAKASH SHARMA),J HEENA/MAHIMA/37