Pre-adjudication GST recovery letters to customers are invalid, but lawful recovery may follow after adjudication.

Letters issued by GST authorities to customers before any order-in-original had crystallised tax liability were invalid and could not support coercive recovery or further action. Where only a tax proposal was pending, such pre-adjudication communication had no legal basis for enforcement. The revenue's right to proceed lawfully after adjudication was preserved, including recovery under Section 79(1)(c) of the GST enactments, and the availability of refund proceedings under Section 54 remained unaffected. The decision therefore distinguishes impermissible pre-assessment coercive communication from lawful post-adjudication recovery.

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Issues: Whether letters issued by the GST authorities to the petitioners' customers, before the issuance of orders-in-original determining tax liability, were valid and could support further coercive action, and whether the revenue retained liberty to proceed with recovery after adjudication.

Analysis: The communication to customers was issued when only a tax proposal was pending and no tax liability had crystallised. In that situation, the prior communication could not be treated as a valid basis for coercive recovery or further action. At the same time, the disposal preserved the revenue's right to initiate lawful recovery proceedings after orders-in-original, including action under Section 79(1)(c) of the applicable GST enactments, and the earlier availability of refund proceedings under Section 54 remained unaffected.

Conclusion: Letters issued before adjudication determining tax liability were held invalid and incapable of sustaining further action, but the revenue was left free to pursue recovery in accordance with law after the orders-in-original.

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