227.            B Ltd., a supplier of taxable goods, has applied for provisional assessment u/s 60 of the CGST Act & paid GST on provisional basis. The Assistant Commissioner issued a show cause notice before finalization of provisional assessment on the ground of misclassification of goods. Discuss the validity of SCN.

A show cause notice can be issued for recovery if GST is not levied or short levied. Before finalization of provisional assessment, the question of non-levy or short levy cannot arise. Thus, the SCN is invalid.