https://www.taxtmi.com/caselaws?id=797115 Section 74 of the GST Act requires subjective satisfaction based on material indicating fraud, concealment or non-payment before its fraud-based assessment mechanism can be invoked. A tax-demand order must disclose the basis for invoking that provision, give reasons for the assessed tax, interest and penalty, and afford an opportunity of hearing; otherwise, it is jurisdictionally defective and non-speaking. Article 226 writ jurisdiction may remain available to correct such an order despite dismissal of a statutory appeal as time-barred. Fresh adjudication after hearing the assessee is required in accordance with law. en-us Wed, 12 Aug 2026 00:00:00 +0530 Mon, 17 Aug 2026 09:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797115 Section 74 of the GST Act requires subjective satisfaction based on material indicating fraud, concealment or non-payment before its fraud-based assessment mechanism can be invoked. A tax-demand order must disclose the basis for invoking that provision, give reasons for the assessed tax, interest and penalty, and afford an opportunity of hearing; otherwise, it is jurisdictionally defective and non-speaking. Article 226 writ jurisdiction may remain available to correct such an order despite dismissal of a statutory appeal as time-barred. Fresh adjudication after hearing the assessee is required in accordance with law. Case-Laws GST Wed, 12 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797115