https://www.taxtmi.com/caselaws?id=757625 A MODVAT credit reversal demand cannot be sustained under Rule 57AH where the show-cause notice invoked only Rule 57U, unless the assessee receives notice and a fair opportunity to address the changed statutory basis. Although an incorrect rule citation does not necessarily invalidate proceedings, substituting a provision that carries materially different consequences, including a longer limitation period, without prior notice breaches procedural fairness. The adjudication order founded on Rule 57AH was therefore set aside, with consequential relief. en-us Thu, 29 Aug 2024 00:00:00 +0530 Fri, 30 Aug 2024 08:36:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=757625 A MODVAT credit reversal demand cannot be sustained under Rule 57AH where the show-cause notice invoked only Rule 57U, unless the assessee receives notice and a fair opportunity to address the changed statutory basis. Although an incorrect rule citation does not necessarily invalidate proceedings, substituting a provision that carries materially different consequences, including a longer limitation period, without prior notice breaches procedural fairness. The adjudication order founded on Rule 57AH was therefore set aside, with consequential relief. Case-Laws Central Excise Thu, 29 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=757625