https://www.taxtmi.com/caselaws?id=794114 Section 74 of the GST enactments permits demand proceedings where prima facie, record-based material establishes jurisdictional facts concerning unpaid or short-paid tax, erroneous refunds, or wrongly availed or utilised input tax credit. The factual basis may emerge from statutory antecedents, including scrutiny, audit, inspection, or communications such as ASMT-10, DRC-01A, ADT-02, ADT-04 and INS-02; it need not be repeated verbatim in the show cause notice. The expression "where it appears to the proper officer" denotes a prima facie threshold rather than a "reason to believe" standard. Challenges alleging absence of foundational facts, predetermination or limitation fail where the statutory record supports initiation, although procedural relief may include time to reply or fresh merits adjudication. en-us Mon, 08 Jun 2026 00:00:00 +0530 Tue, 30 Jun 2026 10:16:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794114 Section 74 of the GST enactments permits demand proceedings where prima facie, record-based material establishes jurisdictional facts concerning unpaid or short-paid tax, erroneous refunds, or wrongly availed or utilised input tax credit. The factual basis may emerge from statutory antecedents, including scrutiny, audit, inspection, or communications such as ASMT-10, DRC-01A, ADT-02, ADT-04 and INS-02; it need not be repeated verbatim in the show cause notice. The expression "where it appears to the proper officer" denotes a prima facie threshold rather than a "reason to believe" standard. Challenges alleging absence of foundational facts, predetermination or limitation fail where the statutory record supports initiation, although procedural relief may include time to reply or fresh merits adjudication. Case-Laws GST Mon, 08 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794114