Show cause notice limits demand: unquantified interest cannot be added later in adjudication beyond the notice.

An adjudication order cannot sustain a tax, interest or penalty demand that goes beyond what was stated in the show cause notice, because demand cannot be confirmed on grounds not specified in the notice. Where interest was not quantified in the notice for the relevant period, the later order could not validly fasten that liability beyond the notice. The provision allowing interest to be payable whether or not specified in the adjudication order applies only to omission in the order, not to omission in the show cause notice. The notice and the adjudication order were therefore quashed to the extent they sustained the impugned demand beyond the notice.

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Issues: Whether an adjudication order confirming tax, interest and penalty can sustain when interest was not quantified in the show cause notice, and whether the interest-saving provision applies where the omission is in the notice rather than in the order.

Analysis: The notice had not quantified the interest for the relevant period, though the liability was later fastened in the adjudication order. The statutory bar prevents confirmation of demand on grounds not specified in the notice, and the demand in the order cannot exceed the notice. The provision making interest payable whether or not specified in the order applies to non-quantification in the adjudication order, not to omission in the show cause notice.

Conclusion: The adjudication order and the show cause notice, insofar as they sustained the impugned demand beyond the notice, were unsustainable and were quashed. The issue is answered in favour of the assessee.

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