Pre-show cause notice consultation under the Master Circular was treated as satisfied after summons, document production, and questioning.

Paragraph 5.0 of the Master Circular seeks to promote trade facilitation and voluntary compliance by reducing avoidable show cause notices. On the facts, repeated summons were issued, documents were produced, and questions were put to the assessee and its representatives; that interaction was treated as sufficient pre-show cause notice consultation even though the precise demand had not yet been framed. The requirement of consultation was therefore treated as satisfied, and interference with the show cause notice at the threshold was declined.

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Issues: Whether the requirement of pre-show cause notice consultation under paragraph 5.0 of the Master Circular dated 10.03.2017 stood satisfied, and whether the show cause notice should be interfered with at the threshold.

Analysis: The object of paragraph 5.0 of the Master Circular is to promote trade facilitation and voluntary compliance by reducing avoidable issuance of show cause notices. On the facts, multiple summons had been issued, documents were produced, and questions were put to the petitioner and its representatives. That interaction was treated as sufficient consultation for the purpose of the circular, even though the precise demand was yet to be framed at that stage.

Conclusion: The requirement of pre-show cause notice consultation was held to be satisfied, and interference with the show cause notice at that stage was declined.

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