Rule 142 of the CGST Rules, 2017— Summary of SCN –Issuance of SCN is mandatory - The petitioners challenged the respective summary of SCN issued under Rule 142 of the Rules, respective adjudication orders and all consequential orders and also the entire adjudication proceedings, on the ground that the revisional authority without passing an order under Section 108 had just returned the revision applications filed by the respective petitioners. The counsels submitted that no show cause notices has been issued under Section 74 and only DRC-01/DRC-02 were issued under Rule 142. DRC-1 is not a substitute of the show cause notice. There is no reference to any relied upon adverse materials. Non grant of relied upon documents with DRC-01 is in violation of principles of natural justice. Demand of tax, interest and penalty have been confirmed on the ground of paper transaction without proper enquiry. It is a case of revenue neutrality; hence, Section 74 cannot be invoked. The court observed that in some cases only penalty order has been passed, in some cases no DRC-01 has been issued. In none of the cases show cause notices as per the provision of the Act has been issued. In a few cases assessment order has been passed but it is not on record that whether the same has been served to the respective petitioners. The counsel for the respondents could not bring on record any such document which can satisfy that proper procedure has been followed in passing the orders. Demand of tax, interest and penalty has been confirmed without proper enquiry. The law is now no more res integra that the show cause notice under Section 73/74 is mandatory in nature. 

Held that:- The Hon’ble High Court set aside the orders and remitted all these matters back to the concerned respondents to pass afresh order in accordance with law after following principles of natural justice.