Section 74 GST action was upheld because the show cause notice...

Section 74 GST action was upheld because the show cause notice and assessment were based on a prima facie discrepancy between the seigniorage fee-linked quantity/value and the lower value disclosed in returns, amounting to alleged suppression of outward supply. The HC held that this was sufficient foundational material for invoking the extended period of limitation, and rejected the challenge that there was no basis for Section 74 proceedings. The natural justice objection also failed because intimation notices and show cause notices had been issued and replies were filed, leaving no procedural defect warranting writ interference. The writ petitions were dismissed, with liberty to pursue the statutory appeal.