Pre SCN Consultation ––- The court perused categorical directions issued by the High Court that SCN dated 11-10-2021 shall be read as “additional information in addition to the audit observation dated 01-10-2021”, with a further direction to the Assessing Officer that the petitioner shall be accorded PH and observed that they are satisfied that there is a substantial compliance to the principle of natural justice and the petitioner has sufficient opportunities to satisfy the Authorities that there is no reason to proceed against it on the basis of show cause notice, which was issued without pre-consultation process.

Held that:- The Hon’ble Court accordingly disposed the SLP and directed that all legal grounds, including limitation, may be raised by the petitioner, which shall be considered by the Competent Authority on its own merits and in accordance with the law.