Jurisdictional facts in GST notices can sustain Section 74 action despite prior audit, leaving factual disputes to adjudication.

Jurisdictional facts for GST show cause notices under Section 74 are treated as sufficient where the notice sets out investigation material, statements, and transaction details supporting allegations of wrong valuation and improper reduction of tax liability through credit notes. The note explains that a local audit and a wider investigation operate in distinct fields, so prior audit or overlap with earlier proceedings does not by itself bar fresh action. It further identifies disputed factual issues as matters for departmental adjudication rather than writ review, indicating that a notice with a separate factual basis will generally not be quashed at the threshold.

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Issues: Whether the impugned show cause notices issued under Section 74 of the GST enactments were without jurisdiction for want of foundational facts, and whether prior audit or earlier investigation barred the present proceedings.

Analysis: The notices recorded allegations of wrong valuation and inadmissible reduction of tax liability through credit notes, based on investigation material, statements, and transaction details spanning multiple States. The Court held that these materials furnished the jurisdictional facts required for invocation of Section 74 and that the scope of a local audit under Section 65 was distinct from a pan-India investigation under Section 67. It further held that overlap with earlier proceedings did not by itself negate jurisdiction, especially where the notice disclosed separate factual bases and the matter involved disputed questions of fact not suitable for writ adjudication under Article 226 of the Constitution of India.

Conclusion: The challenge to the show cause notices failed; the notices were held to be validly issued and the assessee was directed to submit replies for adjudication by the department.

Ratio Decidendi: A writ court will not quash a show cause notice under Section 74 of the GST enactments where the notice discloses jurisdictional facts and supporting material for alleging tax evasion, and disputed factual issues arising from investigation must be left to statutory adjudication.

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