Assessment of unregistered persons must precede GST recovery proceedings, leaving educational institution exemption claims open for determination.

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....Section 63 assessment of a person liable to GST who failed to obtain registration must precede tax-recovery proceedings under section 74. The proper officer must issue notice and make a best-judgment assessment for the relevant period after providing an opportunity of hearing. An educational institution may raise its exemption claim in those assessment proceedings. A recovery show-cause notice issued without first initiating the section 63 process was quashed, while the Department retained liberty to issue notice in ASMT-14 and pursue assessment; the exemption claim and other contentions remained open.....