Revenue cannot invoke GST Section 74 where normal Section 73 limitation expired

Zodiac Energy Ltd. Vs Assistant Commissioner of State Tax (Gujarat High Court) The Hon’ble Gujarat High Court in the case of Zodiac Energy Ltd. v. Assistant Commissioner of State Tax [R/Special Civil Application No. 13397 of 2024, order dated July 17, 2025] held that the revenue authority cannot invoke Section 74 and the extended limitation period of five years without establishing fraud, wilful misstatement, or suppression of facts, and where the normal limitation period under Section 73 has expired, proceedings under Section 74 are impermissible in the absence of such mens rea. Facts: ...