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TMI Blog2023 (12) TMI 73X X X X Extracts X X X X X X X X Extracts X X X X ..... ral justice. The details in the show-cause notice satisfy the per-requisites prescribed in Form GST DRC -01 which is statutory in nature. Thus, the contents of the show-cause notice cannot be termed as deficient or inadequate preventing the petitioner/assessee to prepare and file an effective reply and defend himself before the Proper Officer. If petitioner is of the view that certain additional document/material is required for filing an effective reply to the same, then petitioner could have very well demanded the same from the Proper Officer by disclosing the relevancy of such evidence/material to the issue involved - However, what is noticeable in this case is that no such representation was made by the petitioner pursuant to the show-c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d with a show-cause notice dated 22.04.2022 (Annexure-P/3) u/S. 73 of the M.P. GST Act, 2017 qua the tax period April, 2020 to March, 2021 proposing a demand of Rs. 46,72,08,082/- (including tax, interest and penalty). Along with the said show-cause notice (Annexure-P/3), a summary of show-cause notice was appended which reveals brief facts of case and grounds as scrutiny of return. This is followed by details of tax, interest and penalty demanded given in tabular illustration. The said show-cause notice is further appended with Form GST DRC-01 as prescribed by Rule 142(1) of GST Rules mentioning scrutiny u/S. 61, Rule 99(1) against the column brief facts of the case , followed by table mentioning the amount of tax, interest and penalty due ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... petitioner/assessee and if the Proper Officer would have been of the view that the said material/document is relevant to the issue involved, then the same could have been provided to the petitioner/assessee. 5.1 This Court has already taken this view in a detailed order passed in Writ Petition No.26693/2022 ( Raymond Limited Vs. Union of India and others). 6. However, what is noticeable in this case is that no such representation was made by the petitioner pursuant to the show-cause notice and, therefore, it is presumed that petitioner has no grievance against the show-cause notice. 7. In view of the aforesaid discussion, this Court is afraid that it cannot help the petitioner due to petitioner not having raised the objection of the show-ca ..... X X X X Extracts X X X X X X X X Extracts X X X X
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