JUDGMENT :

Heard Mr. R. S. Mishra, the learned counsel for the petitioner and Mr. S. C. Keyal, the learned counsel appearing on behalf of the GST Department.

2. The instant writ petition has been filed challenging the Demand-cum-Show-Cause Notice issued under C.No.V(15)92/ADJ/ST/COMMR /DIB/2020/7125 dated 31.12.2020 as well as the Corrigendum dated 21.02.2022 and for a direction that the respondent authorities should provide an opportunity of pre-show cause notice consultation to the petitioner.

3. The case of the petitioner is that he is a businessman executing contracts primarily work contracts with Public Sector Undertaking or the Government of India Enterprises under the name and style of M/s Sanjib Das. The petitioner is an assessee registered under Section 69 of the Finance Act, 1994 read with Rule 9 of the Service Tax Rules, 1994 bearing registration No.AGVPD4317LST001.

4. It is the case of the petitioner that the Central Board of Excise and Customs had issued a Master Circular on Show Cause Notice, Adjudication and Recovery dated 10.03.2017 on the subject of “Show Cause Notices, Adjudication Proceedings and Recovery”. In terms with Clause 5 of the said Master Circular, the Cent