The GST department must communicate the reasons for retrospective cancellation in the SCN if they intend to take such action.

The tribunal dropped the demand for PGP, holding it exempt under Notification No. 9/2016-ST and clarificatory circulars. However, it confirmed service tax liability for PGPPM, PGPEM, and EPGP.

Reassessment notice extended ten‑year period under Section 149 cannot revive assessments already barred under the earlier six‑year regime.