Amlegals iconAmlegalsSep 8, 2026

Supreme Court Clarifies Scope of Extended Limitation under Section 74 of CGST Act

Introduction The Hon'ble Supreme Court has recently clarified that Section 74 of the CGST Act cannot be invoked merely by reproducing the expressions "fraud", "wilful misstatement" or "suppression of facts". Where the Department seeks to invoke the extended period of limitation, the show-cause notice ("SCN") must disclose the material facts and circumstances which form the...

Supreme Court Clarifies Scope of Extended Limitation under Section 74 of CGST Act

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Introduction The Hon'ble Supreme Court has recently clarified that Section 74 of the CGST Act cannot be invoked merely by reproducing the expressions "fraud", "wilful misstatement" or "suppression of facts".

Where the Department seeks to invoke the extended period of limitation, the show-cause notice ("SCN") must disclose the material facts and circumstances which form the...

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Introduction The Hon'ble Supreme Court has recently clarified that Section 74 of the CGST Act cannot be invoked merely by reproducing the expressions "fraud", "wilful misstatement" or "suppression of facts". Where the Department seeks to invoke the extended period of limitation, the show-cause notice ("SCN") must disclose the material facts and circumstances which form the...

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