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The HC held that the adjudicatory process was vitiated for breach of natural justice because the show-cause notice failed to disclose the materials underpinning the allegation of tax evasion, depriving the petitioner of an opportunity to reply; such procedural infirmity is incurable at appellate stages. Consequently, the adjudicating authority's rectification order dated 16.10.2023 insofar as it confirmed a demand of Rs. 40,37,877/- was set aside and quashed; the appellate authority's order dated 17.02.2025 upholding that finding and the consequent demand notice of 17.02.2025 were likewise set aside and quashed. The writ petition was disposed of.
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