Extended limitation under GST Section 74 sustained on prima facie suppression of turnover and no procedural irregularity found.

Invocation of the extended limitation period under Section 74 of the GST enactments was upheld where inspection material, the seigniorage fee paid, and the mismatch between the quantity and value of boulders allegedly extracted and the value declared in GSTR-1 gave a prima facie basis to infer suppression of turnover. The challenge also failed on alleged procedural irregularity, as no defect was found that would vitiate the impugned orders. On that footing, interference with the demand and the Section 74 action was declined.

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Issues: Whether the invocation of the extended period of limitation under Section 74 of the respective GST enactments and the consequent demand could be interfered with, and whether any procedural irregularity vitiated the impugned orders.

Analysis: The orders were based on inspection material, the seigniorage fee paid, and the disparity between the quantity/value of boulders allegedly extracted and the value declared in GSTR-1. The Court found that the record disclosed sufficient foundational facts to form a prima facie view of suppression of turnover, justifying action under Section 74. It also found no procedural irregularity warranting interference.

Conclusion: The challenge to the invocation of Section 74 and to the impugned orders failed.

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