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Issues: Whether a show cause notice issued after the commencement of the GST regime could be challenged for not adhering to the pre-GST circular format and whether such alleged defect vitiated the notice.
Analysis: The circular relied upon was issued in the pre-GST context. After the commencement of the GST regime, issuance of show cause notices was governed by the prescribed GST formats, namely Form GST DRC-01 and Form GST DRC-01A. Where a specific post-GST format is prescribed, the objection that the notice did not conform to the earlier circular does not establish illegality in the notice.
Conclusion: The challenge to the show cause notice failed, as the notice was required to conform to the GST-prescribed format and no merit was found in the petitioner's objection.
Ratio Decidendi: Once a specific statutory format is prescribed under the GST regime, a pre-GST circular cannot be invoked to invalidate a show cause notice issued in accordance with the applicable GST framework.