Voluntary GST interest recovery notice is not conclusive adjudication where coercive action depends on non-compliance.

A notice proposing GST interest recovery was read as a call for voluntary compliance, requiring the assessee to work out and deposit the exact quantum of interest. The reference to recovery under section 79 was treated as contingent on failure to comply, so the notice was not a conclusive determination of liability and did not, at that stage, establish denial of natural justice. The challenge to the notice on the ground of pre-decided liability and lack of hearing was rejected, and the assessee was directed to respond before any coercive step.

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Issues: Whether a notice proposing GST interest recovery was invalid on the ground that it reflected a pre-decided liability and did not afford an opportunity of hearing before proposed recovery.

Analysis: The notice was read as one calling upon the petitioner to work out and deposit the exact quantum of interest by way of voluntary compliance. The reference to recovery proceedings under section 79 was treated as contingent upon failure to comply voluntarily. On that reading, the Court found no basis to hold at that stage that the petitioner would be denied a proper opportunity to respond before coercive action, and the petitioner was directed to file a reply to the notice.

Conclusion: The notice was not treated as finally determining interest liability, and the challenge on the ground of denial of hearing was rejected.

Final Conclusion: The writ petition was disposed of with liberty to the petitioner to respond to the notice and with the respondents left free to proceed in accordance with law if voluntary compliance was not made.

Ratio Decidendi: A notice inviting voluntary compliance and indicating consequential recovery only on non-compliance is not, by itself, a conclusive adjudication of liability or a denial of natural justice.

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