M/s Tata Steel Limited vs Union of India

Whether a Show Cause Notice under Section 74 of the CGST Act, without foundational facts of fraud/willful misstatement/suppression, can be sustained --- Held No; the notice is invalid and liable to be set aside.\nWhether the limitation for issuing notice under Section 73/74 is extended by the Supreme Court's order in In Re Cognizance for Extension of Limitation --- Held Yes; the period 15.03.2020 to 28.02.2022 is excluded from limitation.

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