Dear Experts,

Requesting your expert views on the following:

  1. After issuance of audit observations under Rule 101(4), can the department proceed to issue a Show Cause Notice (SCN) under Section 73/74 without issuing the final audit report in Form ADT-02? If that is done, doesn't it lead to procedural lapse? Can this be contested by way of appeal with first appellate authority? 

  2. Once ADT-02 is issued, is it permissible to accept the discrepancies and make full payment through Form DRC-03?

  3. If partial payment is made via DRC-03, can the remaining observations still be contested?

  4. In case of full payment under DRC-03 for the discrepancies noted in ADT-02, is the department still allowed to issue an SCN under Section 73/74 for the same issues?

Regards,

S Ram