The Hon’ble Supreme Court in Tata Steel Limited v. Union of India & Ors. [Civil Appeal arising out of SLP (C) No. 16859 of 2026 dated August 25, 2026] set aside the Show Cause Notice dated June 13, 2025 issued under Section 74 of the Central Goods and Services Tax Act, 2017 (“the CGST Act”) for FY 2018-19 to FY 2020-21 and the consequential Order-in-Original dated December 26, 2025, and held that the foundational facts leading to the inference of fraud, wilful misstatement or suppression must be evident from the notice itself, and that the mere mechanical recital of such words in the notice, without application of mind, cannot enable recovery beyond the normal period of limitation prescribed under Section 73 of the CGST Act.
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