Section 74 valid despite Reasons to believe missing in SCN

The Madras High Court held that proceedings under Section 74 of the GST enactments cannot be invalidated merely because the show cause notice does not expressly record elaborate "reasons to believe", where the proceedings are founded on inspection findings revealing tax discrepancies. 

However, since the assessment order contained material computational errors and the taxpayer had not been afforded an effective adjudication on merits, the Court remanded the matter for fresh consideration after granting an opportunity of hearing.