Extended Limitation Period Under Section 74 of the CGST Act Cannot Be Invoked Without Wilful Suppression
The Hon’ble Karnataka High Court in the case of M/s. NCS Pearson Inc. held that the show cause notice issued under Section 74 of the CGST Act, 2017, alleging willful suppression to invoke an extended limitation period, was illegal and without jurisdiction as the Revenue had full knowledge of all facts from the AAR and AAAR proceedings, and the key jurisdictional fact of willful suppression was not satisfied.