ArticleGST Article

Delhi High Court Holds Premature Issuance of SCN Violates Natural Justice under CGST Act

The Hon’ble Delhi High Court in the case of Varian Medical Systems International India Pvt. Ltd. v. Union of India & Ors. [W.P.(C) 10642/2025 & 13605/2025, order dated October 28, 2025] held that the issuance of a Show Cause Notice (SCN) before the expiry of the reply period for the Pre-SCN violates principles of natural justice, and that audit commencement date under Section 65 of the CGST Act is the date when the taxpayer provides required documents, with audit conclusion and communication of findings within prescribed timelines.