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all probabilities the impugned communication is just an administrative action and the same shall obviously culminate into a show cause notice for adjudication. If that is so, nothing would survive for consideration in the petition.

4. We find substance in the submission of Mr. Ochani as the notice is clearly under Rule 101 (5) of the Central Goods and Services Tax Rules, 2017. Rule 101 (5) reads thus:-

Rule 101 (5).- On conclusion of the audit, the proper officer shall inform the findings of audit to the registered person in accordance with the provisions of sub-section (6) of section 65 in FORM GST ADT-02.

5. We thus find that on conclusion of audit, the proper officer has informed the findings of audit to the registered person in accordance with the provisions of sub-section 6 of Section 65 in Form GST ADT- 02. The apprehension of the petitioner that the recovery will be effected on the basis of such information is misconceived. It is obvious that the GST Department shall take further action in accordance with the provisions of the CGST Act.

6. In such view of the matter, the petition is disposed of.

(SANDESH D. PATIL, J.) (M. S. KARNIK, J.)