Summary of Show Cause Notice along with the attachment containing the determination of tax cannot be said to be a valid initiation of proceedings under Section 73 of CGST Act without issuance of a proper Show Cause Notice (SCN) | Authentication in the manner stipulated in Rule 26 (3) of the CGST Rules has to be applied as and when the Proper Officer is required to issue notice or Statement and pass Order | An opportunity of hearing should be granted when a request is received in writing from the person chargeable with tax or penalty or when any adverse decision is contemplated against such person – Md Shoriful Islam Vs. The State of Assam and Ors. – Gauhati High Court

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