GST Appellate Tribunal Rules Adjudication Cannot Shift Grounds Beyond Show-Cause Notice

The GST Appellate Tribunal recently ruled that a Goods and Services Tax demand cannot be confirmed on factual or legal grounds different from those stated in the original show-cause notice. Under Section 75(7) of the relevant legislation, adjudication is strictly restricted to the specific grounds that were initially put to the taxpayer.

This decision prevents tax authorities from introducing new allegations at the final order stage without giving the taxpayer prior notice and an opportunity to respond. It reinforces procedural fairness by ensuring that defense strategies prepared against the show-cause notice remain valid throughout the adjudication process.

Taxpayers facing mismatched demands should review their show-cause notices against final adjudication orders to challenge any unauthorized shifts in grounds. Practitioners must use this ruling to contest orders that introduce new legal or factual arguments not present in the initial notice.