Reply sent by e mail cannot be ignored

The petitioners were unable to file their replies on the GST common portal and were therefore communicating with the Department by email. 

They submitted detailed replies to the show cause notices to the email address provided by the adjudicating authority, but the final order recorded that no reply had been filed. 

The Revenue could not specifically deny receipt of the replies. The High Court held that once the reply had been sent to the authority's own email address, the authority was obligated to consider it.