Penalty Proceeding u/s 129 without issue of notice in Mov-07 - Goods and Services Tax - GST

1. Can Penalty Proceeding u/s 129 be started on the basis of GST DRC-01 (summary of show cause notice) without issue of GST MOV-07 -notice as prescribed vide Circular No.41/15/2018-GST dated 13th April,2018 ? 2. Officer has issued only summary of order in GST DRC-07 , no order has been issued in GST MOV-09 as prescribed. Is it valid order for recovery of demand