https://www.taxtmi.com/caselaws?id=787654 Payment of tax before issuance of a show cause notice attracts statutory protection under Section 73(3) of the Finance Act, 1994, barring notice in respect of the paid amount; this protection is lost only if circumstances enumerated in Section 73(4) (fraud, collusion, wilful misstatement, suppression, or deliberate contravention to evade tax) are specifically pleaded and proved. Invocation of Section 73(4) operates as an exception that also extends limitation and therefore requires clear allegation and demonstration in the notice or record; where the Revenue failed to plead or prove such facts, the protection applies and demand must be set aside. en-us Thu, 19 Feb 2026 00:00:00 +0530 Tue, 10 Mar 2026 08:52:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787654 Payment of tax before issuance of a show cause notice attracts statutory protection under Section 73(3) of the Finance Act, 1994, barring notice in respect of the paid amount; this protection is lost only if circumstances enumerated in Section 73(4) (fraud, collusion, wilful misstatement, suppression, or deliberate contravention to evade tax) are specifically pleaded and proved. Invocation of Section 73(4) operates as an exception that also extends limitation and therefore requires clear allegation and demonstration in the notice or record; where the Revenue failed to plead or prove such facts, the protection applies and demand must be set aside. Case-Laws Central Excise Thu, 19 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787654