Recovery can’t be made merely on basis of notice; assessment order is a must to proceed for recovery

CST & VAT : Where Assessing Authority being of opinion that assessee had availed benefit of input tax credit related to exported goods though not entitled issued notice under section 44 and called upon it to deposit with department a sum of Rs. 6.35 crores, since no order of assessment or any other order of quantification of assessee's liability was passed, straightway ordering recovery was wholly not permissible