GST recovery on disclosed works-contract price adjustments requires material showing deliberate evasion to invoke the extended limitation period.

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....Extended GST recovery under Section 74(1) requires a material-based conclusion, discernible from the show cause notice, that non-payment resulted from fraud, wilful misstatement or suppression of facts with intent to evade tax. Mere non-payment or erroneous self-assessment under a bona fide belief is insufficient, and an approaching limitation deadline cannot replace the statutory preconditions. A writ challenge under Article 226 may be maintained at the show cause stage where jurisdictional conditions are absent, notwithstanding the availability of statutory remedies. An authority cannot establish jurisdiction by incorrectly determining the conditions governing its power.....