https://www.taxtmi.com/forum/issue?id=119927 A prior show cause under Section 73 was followed by payment via DRC-03 and the proceedings were dropped; a fresh DRC-01A notice under Section 74 now seeks to reopen the same period. Section 73 applies to non-fraudulent shortfalls while Section 74 requires material showing fraud, suppression, or willful misstatement. Absent distinct new evidence of fraud, re-initiating under the fraud provision is legally untenable and may amount to abuse of process; the advised response is a DRC-06 reply and a representation to the proper officer, with judicial review as a last resort. en-us Fri, 25 Apr 2025 18:54:45 +0530 Tue, 29 Apr 2025 11:02:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/forum/issue?id=119927 A prior show cause under Section 73 was followed by payment via DRC-03 and the proceedings were dropped; a fresh DRC-01A notice under Section 74 now seeks to reopen the same period. Section 73 applies to non-fraudulent shortfalls while Section 74 requires material showing fraud, suppression, or willful misstatement. Absent distinct new evidence of fraud, re-initiating under the fraud provision is legally untenable and may amount to abuse of process; the advised response is a DRC-06 reply and a representation to the proper officer, with judicial review as a last resort. Discussion-Forum GST Fri, 25 Apr 2025 18:54:45 +0530 https://www.taxtmi.com/forum/issue?id=119927