Extended limitation notices require pleaded fraud or suppression with intent to evade tax, otherwise they are unsustainable.

Extended limitation notices require pleaded fraud or suppression with intent to evade tax, otherwise they are unsustainable.Case-LawsGSTExtended limitation under Section 74 of the SGST/CGST Act requires a show-cause notice to specifically allege fraud,…

Extended limitation notices require pleaded fraud or suppression with intent to evade tax, otherwise they are unsustainable.
Case-Laws
GST
Extended limitation under Section 74 of the SGST/CGST Act requires a show-cause notice to specifically allege fraud, wilful misstatement, or suppression of material facts with intent to evade tax. A notice issued for the relevant tax period without disclosing these statutory ingredients cannot be sustained. The impugned notice was quashed, while the tax authorities retained liberty to issue a fresh notice in accordance with law.
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