Expansion of show cause notice at appellate stage requires a chance to respond before refund rejection is reconsidered.

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....Expansion of a show cause notice at the appellate stage cannot support rejection of accumulated input tax credit refunds without allowing the taxpayer to answer the added grounds. The High Court treated the notice as the foundation of proceedings and found that reliance on grounds introduced only in appeal deprived petitioners of an effective opportunity to reply. Without examining the merits of those grounds or the refund claim, the High Court set aside the adjudication and appellate orders and remitted the matter for fresh adjudication, requiring a comprehensive reply opportunity and personal hearing.....