Revenue's Show Cause Notices Cannot Rely on Office Memoranda or Executive Instructions, Ensuring Adjudicatory Integrity.

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....Scope of the SCN - It is completely impermissible for the Revenue to issue a Show Cause Notice and, thereafter, seek to support, or even supplement, the recitals in the Show Cause Notice by way of Office Memoranda, or executive instructions, such as the Office Memorandum dated 16th February, 2018, under challenge in these writ petitions. - Such an attempt would result in reducing the adjudicatory process to a mockery, and deserves to be deprecated.....