— Show cause notice — Scope — Critical importance of a well-formulated show cause notice in upholding fair trial and due process — Scope — The issuance of a show cause notice is the most crucial in the context of a fair trial and due process — It enables a tax payer to precisely know what allegations are to be met, explained and answered to the satisfaction of the adjudication officer — It is the duty of the Department to ensure that a show cause notice is issued after a proper inquiry and investigation — It should be manifest from the contents of the show cause notice that it was issued after ascertaining the facts and the allegations are not vague or ambiguous — The charges or allegations should be specific, otherwise the taxpayer would be prejudiced and denied the right to a fair trial — As a corollary, the adjudication authority has to confine the proceedings to the specific charges and allegations clearly mentioned in a show cause notice and cannot adjudicate any charge or allegation beyond it — Adjudicating a charge or allegation not confronted in the show cause notice would not be sustainable in law. [2023 SCLR 60 = 2023 SCMR 2070 = 2023 SCP 257]