GST notices and appeals: evidence, hearings and reasoned orders

CBIC Circular 258/04/2026-GST, dated 26 October 2026, gives detailed guidance on GST demands, adjudication, rectification and first appeals.

A show-cause notice should identify the disputed transactions, periods, evidence, legal grounds and calculation of demand. Allegations of fraud, wilful misstatement or suppression require specific supporting material; a mismatch or unpaid tax alone does not automatically establish an intention to evade tax.

Taxpayers should receive the hearing opportunity required by law. Orders should address material submissions and evidence, explain their conclusions and remain within the notice’s grounds and amounts. Prescribed summaries must accompany portal records.

Rectification is limited to apparent errors and cannot replace an appeal on disputed legal or factual issues. Existing appeal limits remain relevant; the circular does not create a fresh filing window.

Businesses should preserve notices and service dates, prepare an evidence-based reply, request a hearing where appropriate and separately track appeal deadlines. A procedural defect should be assessed against the actual record, without assuming automatic cancellation of liability.