GST valuation notices must disclose the applicable rule; confirmation on a different rule violates natural justice.

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....GST valuation proceedings require the show-cause notice to identify the valuation rule on which the proposed demand rests. Where a notice invokes Rule 28(a), but the adjudicating authority finds that rule inapplicable and instead confirms the demand under Rule 27(c), the taxpayer must receive notice and an opportunity to respond to that distinct basis. Substituting the valuation rule at adjudication causes prejudice and breaches natural justice. A fresh show-cause notice is required before proceedings may be pursued on the revised valuation basis.....