Section 73 or 74

In certain situations, the issuance of a notice under Section 73 by the Revenue officer may lack any grounds for malafide parameters, leading to concerns about strategic maneuvers through the back door using Section 74. This tactic, often employed due to time limitations, can be exceptionally frustrating for the affected company, given the substantial penalties imposed, sometimes matching the tax demand itself. Notably, some notices solely reference documents like GSTR 1, GSTR 3B, 9 & 9C, with Section 74 being invoked. Interestingly, an RTI inquiry in a specific Commissionerate revealed that all notices issued in the preceding three years were under Section 74. Please do read the snapshot by J the App by JustIDT and do share your thought and inputs as to how this furstrating situation can be well avoided.