Can new issues be raised in SCN when the ADT 02 is raising those?

[Lokesh Chajed]

GST DESK Audit was initiated for FY 2019-20. The relevant documents were submitted and finally ADT-02 was issued by a particular officer (Say 'A'). Post the ADT-02, DRC-01A was also issued by the same officer and accordingly a reply was filed by the Taxpayer.

Now, (due to a transfer of officer) the audit authority has changed in the meanwhile and a new officer 'B' has taken the position. He is raising new issues in the SCN being issued which were neither covered in ADT 02 issued nor in the DRC 01A issued.

Question is: Can there be new issues raised in the SCN when the ADT 02 and DRC 01A ssued already are not covering these matters? Can the SCN transverse beyond the scope of the issues raised in ADT 02 and DRC 01A ?

AI Summary

Debate on Introducing New Issues in SCN Post ADT-02 and DRC-01A in GST Audit A discussion on a forum addresses whether new issues can be introduced in a Show Cause Notice (SCN) after the issuance of ADT-02 and DRC-01A in a GST audit. The original query involves a change in audit authority, with the new officer raising issues not covered in earlier documents. Responses vary: one participant asserts that new issues cannot be introduced in an SCN after investigation completion, while another suggests that challenging the SCN's validity might not be successful, advising a review of Section 160(1). Others discuss procedural aspects and jurisdictional authority concerning ADT-02 and SCN issuance.