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    Statutory GST appellate limitation cannot ordinarily be bypassed through writ jurisdiction after it has expired following unexplained delay.
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Proposals for suo-moto audit or scrutiny under the HGST Act,...

Suo-moto audit and scrutiny proposals require documented reasons, estimated evasion, DETC recommendation and range-level approval before initiation.

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GST - States July 17, 2026 Circulars
Proposals for suo-moto audit or scrutiny under the HGST Act, 2017 must state clear, specific and duly justified reasons, supported by available records, intelligence inputs, data analysis or another verifiable information source. Each proposal must also specify the tentative quantum of tax evasion. The concerned DETC must first examine and recommend the proposal, after which the case file must be sent to the Joint Excise and Taxation Commissioner (Range) for necessary approval. Field formations must comply strictly; suo-moto action initiated without this prescribed process will be viewed seriously.

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Acts Income Tax