Supreme Court Says Section 74 cannot be invoked by a bare allegation

For FY 2018-19, G.R. Infra Projects received a GST show cause notice under Section 74 on 13 June 2025. 

The Supreme Court held that the Section 73 limitation had expired on 28 February 2025 and that the Department could not rescue the notice by elaborating allegations of fraud or suppression for the first time in its counter-affidavit. 

The notice itself merely used the expressions "fraud or concealment of facts" without explaining the basis for either. The SCN was therefore set aside.