GST show cause notices issued before expiry of the Section 74...

GST show cause notices issued before expiry of the Section 74 limitation were not time-barred, so the bar of limitation failed. Invocation of the fraud/suppression machinery was also sustained where notices were preceded by DRC-01A intimations and the petitioner had not replied for some tax periods, leaving the matter to be tested through reply and adjudication. Because disputed factual issues arose and each tax year was treated as an independent block, the writ challenge to the notices was not entertained at the notice stage. The writ petitions were dismissed, with liberty to file replies and a direction that final orders be passed after notice and hearing.