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Sections 73 and 74 of the CGST Act permit a common show cause notice covering multiple tax periods or financial years, as the expressions "for any period" and "such periods" do not impose a financial-year-specific bar. Financial-year references in the order-limitation provisions operate as separate limitation benchmarks for each demand component; consolidation cannot extend limitation or defeat period-wise objections. Section 74 requires disclosed material supporting fraud, wilful misstatement or suppression of facts to evade tax, and cannot be invoked merely because tax remains unpaid. Rule 142 and FORM GST DRC-01 regulate electronic notice communication without restricting consolidation. Notice-specific allegations, quantified demands, hearing rights, reasoned orders and limits on confirmation remain applicable.
Sections 73 and 74 of the CGST Act permit a common show cause notice covering multiple tax periods or financial years, as the expressions "for any period" and "such periods" do not impose a financial-year-specific bar. Financial-year references in the order-limitation provisions operate as separate limitation benchmarks for each demand component; consolidation cannot extend limitation or defeat period-wise objections. Section 74 requires disclosed material supporting fraud, wilful misstatement or suppression of facts to evade tax, and cannot be invoked merely because tax remains unpaid. Rule 142 and FORM GST DRC-01 regulate electronic notice communication without restricting consolidation. Notice-specific allegations, quantified demands, hearing rights, reasoned orders and limits on confirmation remain applicable.
Note: It is a system-generated summary and is for quick reference only.