Section 74 fraud allegations must be particularised; an ITC mismatch alone cannot sustain a notice for wrongful credit.

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....Section 74 of the HPGST Act requires a show cause notice to state the foundational facts showing that wrongful availment or utilisation of input tax credit resulted from fraud, wilful misstatement, or suppression of facts to evade tax. Bare, alternative recitals of those expressions, without identifying the taxpayer's precise conduct and linking it to the alleged default, do not meet that requirement. An ITC mismatch or short payment alone cannot justify Section 74 unless the notice records supporting reasons and facts. The High Court set aside the defective notice, permitted a fresh notice within 60 days without limitation bar, and kept the challenge to ITC provisions open.....