Fraud-based GST recovery requires show cause notices to state foundational facts, not merely recite statutory grounds.

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....Section 74(1) may be invoked for delayed GST payment only where the show cause notice discloses foundational facts permitting an inference of fraud, wilful misstatement, or suppression with intent to evade tax. Mere mechanical reproduction of those statutory expressions does not satisfy that condition. Because the notice contained no such factual basis, recourse to section 74(1) was unwarranted; the Tribunal sustained the setting aside of the proceedings and dismissed the Revenue's appeal.....