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Show cause notice can't be issued to debtors till tax liability isn't finalised

Show cause notice can't be issued to debtors till tax liability isn't finalised

The service tax department should first pass the order on the show cause notice (i.e. adjudicate) and then only can proceed to issue intimations to bank (debtors) to freeze the account or carry out any other recovery proceedings. The SC has held that the tax due means ascertained liability for taxes, and it does not merely mean a liability created by the charging sections.