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TMI Blog2025 (2) TMI 734X X X X Extracts X X X X X X X X Extracts X X X X ..... the assessee to the final audit report and thereafter has drawn the show-cause notice. However, on a closer reading, it is seen that the adjudicating authority has extracted the reply given and in a single line stated that "The decision by the undersigned on the above discrepancy stands and hence the liability remains as:" What is required to be seen is whether this would tantamount to a proper show-cause notice. It is settled legal proposition that a show-cause notice should be specific as to the role of the assessee and as to what passes in the mind of the adjudicating authority, which, in its prima facie view is against the assessee. If the show-cause notice does not satisfy these conditions, the notice will be termed as 'unspecific' a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y Chakraborty Mr. S. Sanyal. JUDGMENT (T.S. SIVAGNANAM, C.J.) 1. This intra-Court appeal by the writ petitioners is directed against the order dated January 15, 2025 in W.P.A. 28834 of 2024. In the said writ petition, the appellants had challenged a show-cause notice issued under Section 73 of the CGST Act dated November 19, 2024. 2. The learned Single Bench was of the view that the appellants should submit to the jurisdiction, furnish their reply and participate in the adjudication process. Aggrieved by the same, the appellants are before us by way of this appeal. 3. We have elaborately heard Mr. Ankit Kanodia, learned advocate for the appellants and Mr. T.M. Siddique, learned Senior advocate appearing for the respondents. 4 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o a proper show-cause notice. 6. It is settled legal proposition that a show-cause notice should be specific as to the role of the assessee and as to what passes in the mind of the adjudicating authority, which, in its prima facie view is against the assessee. If the show-cause notice does not satisfy these conditions, the notice will be termed as 'unspecific' and 'vague' thereby denying opportunity to the assessee to put forth an effective reply. 7. When we examined the scheme of the Act, we find that sub-section (6) of Section 65 states that on conclusion of audit, the proper officer shall, within thirty days, inform the registered person, whose records are audited, about the findings, his rights and obligations and the reasons for such ..... X X X X Extracts X X X X X X X X Extracts X X X X
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