Fraud and willful misstatement required to invoke extended GST assessment period; demands must rest on evidential findings.
Invocation of the extended assessment provision requires material evidence of fraud, willful misstatement, or suppression of facts to evade tax; non-payment alone does not justify using the extended period. Instruction No. 05/2023 instructs that such evidence must be part of the show cause notice, and taxpayers may rely on this clarification when contesting demands issued under the extended assessment provision. (AI Summary)