Audit Closure Bars Reopening of Same Issues Under Section 73

The Hon’ble Gauhati High Court in the case of M/s. Surya Businees Private Limited vs State of Assam & Ors [WP(C)/6322/2023, order dated March 05, 2026] held that once audit proceedings under Section 65 of the CGST/AGST Act had concluded and the assessee had discharged the liability determined in the final audit report, issuance of a subsequent show cause notice under Section 73 for the same period and same issues was not maintainable in absence of circumstances contemplated under Section 65(7) of the Act.

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