Proper GST notice and meaningful hearing are mandatory; summary forms cannot replace statutory notice, and the demand was quashed.

A GST demand cannot stand where adjudication proceeds only on a summary in Form GST DRC-01 without a proper show cause notice setting out the foundational allegations; the proceedings were therefore unsustainable and the adjudication order was void. The order also failed because no separate personal hearing notice was issued, no effective opportunity to respond was given, and the record did not support the stated date or manner of the order, amounting to breach of statutory hearing requirements and natural justice. The impugned notices, adjudication order, and summary orders were quashed, with liberty to proceed afresh in accordance with law.

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Issues: (i) Whether the adjudication proceedings and consequential demand could be sustained without issuance of a proper show cause notice under the GST framework. (ii) Whether the adjudication order was liable to be set aside for violation of the mandatory opportunity of hearing requirements and for the irregular manner in which the order was recorded and communicated.

Issue (i): Whether the adjudication proceedings and consequential demand could be sustained without issuance of a proper show cause notice under the GST framework.

Analysis: The proceedings arose from inspection and were followed only by a summary of show cause notice in Form GST DRC-01. No proper show cause notice under the relevant GST provisions was issued, and the summary did not contain the foundational allegations necessary to answer the case against the assessee. A summary form cannot substitute the statutory requirement of a proper notice that clearly informs the person chargeable with tax of the precise allegations to be met.

Conclusion: The proceedings were unsustainable and the adjudication order was non est for want of a proper show cause notice.

Issue (ii): Whether the adjudication order was liable to be set aside for violation of the mandatory opportunity of hearing requirements and for the irregular manner in which the order was recorded and communicated.

Analysis: The record disclosed that no separate notice fixing a date of personal hearing was issued, no effective opportunity was granted before adverse determination, and the order-sheet did not support the alleged date of the adjudication order. The mandatory hearing safeguards under the GST provisions were not followed, and the manner in which the order was later produced and reflected in the summary order reinforced the procedural illegality. The proceedings were therefore contrary to the principles of natural justice and the statutory hearing requirements.

Conclusion: The adjudication order and the connected summaries were liable to be quashed for violation of natural justice and statutory hearing requirements.

Final Conclusion: The impugned GST notices, adjudication order, and summary orders were quashed, while the tax authorities were left free to proceed afresh in accordance with law.

Ratio Decidendi: A demand under the GST law cannot be sustained unless it is preceded by a proper show cause notice and a meaningful opportunity of hearing in accordance with the statute and the principles of natural justice.

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