Defective show cause notice cannot be cured on appeal; absent basic allegations and particulars, the demand fails.

A show cause notice must clearly and substantively set out the allegations with supporting particulars; where the basic allegations are absent or unsubstantiated, the defect cannot be cured later by fresh arguments on appeal. A challenge based on the nature of kiering or bleaching did not remedy the foundational defect in the notice, so the Revenue's appeal was rejected.

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Issues: Whether the demand could be sustained when the show cause notice did not clearly and substantively set out the allegations against the assessee, and whether the alleged defect could be cured at the appellate stage.

Analysis: The notice had to state the allegations clearly and with supporting particulars. Where the basic allegations were absent or remained unsubstantiated, the deficiency could not be corrected later by advancing new arguments on the merits of the process undertaken by the assessee. The challenge based on the nature of kiering or bleaching did not cure the foundational defect in the notice.

Conclusion: The Revenue's appeal was rejected because the show cause notice was insufficiently substantiated and the defect could not be remedied in second appeal.

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