Natural justice and scope of show cause notice require an order to stay within pleaded allegations and allow a fair hearing.

An adjudication order that raises allegations outside the scope of the show cause notice is liable to be set aside for breach of natural justice, because the affected party must have a fair opportunity to meet the case made against it. Here, the order introduced alleged suppression based on differences between the profit and loss account and returns, and non-filing of GSTR-9 and GSTR-9C, although those matters were not covered by the notice. The order was set aside, with liberty to treat it as a show cause notice, file objections, and proceed to a fresh decision after hearing.

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Issues: Whether the impugned order was liable to be set aside for travelling beyond the scope of the show cause notice and for violation of natural justice.

Analysis: The impugned order introduced issues relating to alleged suppression based on the difference between the profit and loss account and the returns, and also non-filing of annual return in GSTR 9 and GSTR 9C, although these matters were not covered by the show cause notice. The petitioner therefore had no opportunity to meet those allegations. The respondent also indicated that the petitioner could be permitted to treat the impugned order as a show cause notice and submit objections, followed by a fresh decision after hearing.

Conclusion: The impugned order was set aside for having gone beyond the show cause notice and for denial of a proper opportunity to respond.

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