Whether a Demand-cum-Show Cause Notice (SCN) issued under Section 73 of the CGST Act, 2017, based solely on discrepancies noticed in the returns filed, could have been validly issued by Proper Officer without due compliance with the procedure prescribed under Section 61 read with Rule 99 of the CGST Rules – Pepsico India Holdings Pvt. Ltd. Vs. The Union of India and Ors. – Gauhati High Court