226.            Department issued a letter to Mr. A specifying that A is ineligible for exemption. The taxable person contend that the adjudication was passed without giving show cause notice, thus, the same is invalid. Discuss

A mere letter from the department specifying that taxable person was ineligible for exemption cannot be regarded as show cause notice, being communication or advices from department is not show cause notice. Therefore, any adjudication order passed without SCN is invalid.