https://www.taxtmi.com/article/detailed?id=17320 Section 74 of the CGST Act permits extended limitation only where fraud, wilful misstatement, or suppression of facts is supported by disclosed foundational facts. An ITC mismatch, short payment, audit objection, or general allegation of suppression may justify enquiry but cannot alone establish culpable conduct. A show-cause notice must identify the alleged withheld or misstated fact, the disclosure obligation, and its connection with the proposed tax consequence. Statutory terminology, protective demands, or later allegations cannot cure the absence of a jurisdictional basis in the notice. en-us Mon, 31 Aug 2026 08:29:32 +0530 Mon, 31 Aug 2026 08:29:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/article/detailed?id=17320 Section 74 of the CGST Act permits extended limitation only where fraud, wilful misstatement, or suppression of facts is supported by disclosed foundational facts. An ITC mismatch, short payment, audit objection, or general allegation of suppression may justify enquiry but cannot alone establish culpable conduct. A show-cause notice must identify the alleged withheld or misstated fact, the disclosure obligation, and its connection with the proposed tax consequence. Statutory terminology, protective demands, or later allegations cannot cure the absence of a jurisdictional basis in the notice. Articles Goods and Services Tax - GST Mon, 31 Aug 2026 08:29:32 +0530 https://www.taxtmi.com/article/detailed?id=17320