The assessment order was passed making addition u/s. 68 of the Act, without issuing the show cause notice. On writ the Court held that the issuance of show cause notice is the preliminary step is required to be understanding. The purpose of show cause notice is to enable a party effectively deal with the case made out by the respondent. On the facts the addition was made without issue of show cause notice, the order was  quashed and set aside. Followed  Om Shri Jigar Association v.UOI,1994 SCC Online.Guj  77.