Procedural fairness in GST notices: ensure intimation precedes show cause notice and allow reasonable opportunity to reply.
The case addresses non-compliance with GST notice procedures where intimation in Form GST DRC-01A and a show cause notice under Section 74(1) were issued simultaneously, depriving the taxpayer of a statutory opportunity to reply. Emphasising procedural fairness and the right to a fair hearing, the court required that the taxpayer be allowed to file a response within a specified timeframe and that further proceedings, including any fresh notice, follow after consideration of that reply.