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.
TMI Updates – Highlights, quick notes, marquee, annotation, news, alerts
= = = = = = = =
Plain text (Extract) only
For full text:-Visit the Source
= = = = = = = =