Relevant date for show cause notice: counted from due date for filing annual return; differing adjudication timelines follow.

The relevant date for issuing a show cause notice is the due date for filing the annual return for the financial year to which the demand relates. Non-fraud cases must be adjudicated within three years from that due date, with the notice issued at least three months before the adjudication deadline. Fraud, suppression of facts, or willful misstatement cases must be adjudicated within five years from that due date, with the notice issued at least six months before the adjudication deadline.

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