Year-wise GST tax periods make composite show cause notices impermissible, requiring separate proceedings despite contrary non-jurisdictional preceden...
GST adjudication orders that expressly incorporate annexures must be read as composite instruments. A digitally signed portal-generated order can validly authenticate an accompanying annexure containing the reasons, input tax credit determination and consequential liability; an inconsistent portal recital that proceedings were dropped does not sever or invalidate the incorporated annexure. Rectification may correct an error apparent from the record to reflect the decision actually made, but cannot reopen merits or create a fresh adjudication. No further hearing is required where the correction does not adversely alter the taxpayer's original position. FORM GST DRC-07 is a statutory summary rather than the adjudication itself, but DRC-07 and corresponding DRC-08 must be made available within a reasonable time to permit appeal and demand enforcement.
GST adjudication orders that expressly incorporate annexures must be read as composite instruments. A digitally signed portal-generated order can validly authenticate an accompanying annexure containing the reasons, input tax credit determination and consequential liability; an inconsistent portal recital that proceedings were dropped does not sever or invalidate the incorporated annexure. Rectification may correct an error apparent from the record to reflect the decision actually made, but cannot reopen merits or create a fresh adjudication. No further hearing is required where the correction does not adversely alter the taxpayer's original position. FORM GST DRC-07 is a statutory summary rather than the adjudication itself, but DRC-07 and corresponding DRC-08 must be made available within a reasonable time to permit appeal and demand enforcement.
Note: It is a system-generated summary and is for quick reference only.