Interest Quantification: interest not quantified in a show cause notice cannot be imposed in the adjudication order; fresh notice allowed.

The note addresses whether interest not quantified in a show cause notice can be imposed in a GST adjudication order. It applies the principle that the adjudicating order cannot demand amounts or grounds beyond those specified in the show cause notice, relying on the statutory bar on exceeding notice-specified demands; while the statute permits interest to be payable even if omitted from an order, that provision does not validate omission from the notice. The court quashed the notice and order to the extent interest was imposed without quantification and allowed reissue of a fresh notice in accordance with law.

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Issues: (i) Whether interest for a period not quantified in the show cause notice can be imposed in the adjudication order under the Goods and Services Tax Act, 2017.

Analysis: Section 75(7) of the Goods and Services Tax Act, 2017 provides that the amount of tax, interest and penalty demanded in the order shall not exceed the amount specified in the notice and no demand shall be confirmed on grounds other than those specified in the notice. Section 75(9) of the Goods and Services Tax Act, 2017 states that interest on tax short paid or not paid shall be payable whether or not specified in the order determining tax liability; however, Section 75(9) addresses omission in the adjudication order, not omission in the show cause notice. The show cause notice issued November 29, 2024 did not quantify interest for April 2020 to March 2021, a period known to authorities when issuing the notice. Imposing interest in the adjudication order beyond amounts and grounds specified in the show cause notice contravenes Section 75(7).

Conclusion: The impugned show cause notice and the order under Section 73(9) of the Goods and Services Tax Act, 2017 are quashed and set aside to the extent interest was imposed without quantification in the notice; the authorities may issue a fresh show cause notice in accordance with law.

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