Suppression cannot be presumed for Sec 74

The Gujarat High Court has drawn a clear line on Section 74 of the CGST Act that a tax dispute is not automatically a suppression case. 

Where the transaction is disclosed and the dispute is essentially about the interpretation of GST law, the Revenue must still establish deliberate suppression coupled with an intent to evade tax. 

The Court therefore quashed the Section 74 proceedings, reinforcing that tax short-paid does not, by itself, mean wilful suppression.