Foundational facts in fraud-based GST notices are mandatory; unsupported fake-invoice input tax credit allegations cannot sustain proceedings.

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....GST notices alleging fraud, wilful misrepresentation or suppression must disclose the foundational facts supporting those allegations. Mere reproduction of statutory expressions, without reasons showing application of mind, does not sustain proceedings alleging input tax credit availed through fake invoices without actual supply of goods. Notices lacking sufficient reasons were quashed, while preserving the authority's liberty to issue fresh notices in accordance with law.....