Opportunity to be heard: Tax authorities must follow prescribed GST notice and procedure before raising demands. Tax demands under the TGST Act, 2017 must be raised only after following the statutory procedure and issuing prescribed notices; jurisdictions have been observed initiating non-filer assessments and enforcement without issuing the required notice to return defaulters and without following the procedure set out in the GST scheme and applicable SOP. Taxpayers must be afforded a reasonable opportunity to present their case before demands are finalized or recovery actions commence.