registered person is required to be put on notice and called upon to show cause notice with regard to the amounts payable by him in respect of tax, interest and penalty, whether such liability arises out of non-payment, short payment, erroneous refund or wrongful availment or utilization of input tax credit. As regards liability in respect of credit notes, on perusal of the show cause notice, liability was computed therein. However, the petitioner was merely called upon to provide copies of original invoices and credit notes to verify eligibility and not called upon to show cause. As regards eligibility in respect of input tax credit claimed by the petitioner, the show cause notice merely indicated the amounts claimed by the petitioner as input tax credit in its GSTR 3B returns and called upon the petitioner to provide invoice-wise details. There was no indication in the show cause notice of the proposal to reversal input tax credit or otherwise impose tax liability. Turning to tax liability on other income reported in the profit and loss account, the show cause notice referred to three sources of income from the profit and loss account and specified the amounts mentioned in the profit and loss account in respect of these three sources of income. Beyond that, no indication of the petitioner's
