https://www.taxtmi.com/caselaws?id=797713 Extended limitation under Section 74 of the CGST Act cannot be invoked after Section 73 limitation expires unless the notice states foundational facts supporting fraud, wilful misrepresentation or suppression causing tax shortfall or excess input-tax credit. Extended annual-return due dates and pandemic-related exclusion made the ordinary three-year limitation expire on 28 February 2025; a notice issued thereafter was time-barred under Section 73. A bare allegation of suppression, reliance on omitted Explanation 2, or a protective demand cannot establish the required satisfaction. The Section 74 notice and consequential order-in-original were set aside, while fresh Section 74 proceedings remain permissible on properly pleaded facts if concluded before 28 February 2027. en-us Tue, 25 Aug 2026 00:00:00 +0530 Wed, 26 Aug 2026 11:49:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797713 Extended limitation under Section 74 of the CGST Act cannot be invoked after Section 73 limitation expires unless the notice states foundational facts supporting fraud, wilful misrepresentation or suppression causing tax shortfall or excess input-tax credit. Extended annual-return due dates and pandemic-related exclusion made the ordinary three-year limitation expire on 28 February 2025; a notice issued thereafter was time-barred under Section 73. A bare allegation of suppression, reliance on omitted Explanation 2, or a protective demand cannot establish the required satisfaction. The Section 74 notice and consequential order-in-original were set aside, while fresh Section 74 proceedings remain permissible on properly pleaded facts if concluded before 28 February 2027. Case-Laws GST Tue, 25 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797713