GST demand limitation bars late notices unless extended recovery is supported by foundational fraud or suppression facts.

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....GST demand limitation under Section 73 runs from the due date for the annual return; extensions of those due dates change its commencement, and pandemic-period exclusion must be applied when calculating the three-year period. A notice issued after the resulting deadline cannot be sustained under the ordinary limitation. Recourse to Section 74's five-year period requires the Assessing Officer's satisfaction, based on disclosed foundational facts, that fraud, wilful misstatement or suppression caused the tax shortfall or excess input tax credit. Audit objections and bare statutory assertions are insufficient. The show-cause notice and consequential order were set aside, with liberty for fresh Section 74 proceedings within the applicable extended limitation.....