section 74 - Goods and Services Tax - GST

A single show cause notice under Section 74 was issued for the years 2017-18, 2018-19, 2019-20, 2020-21, and 2021-22, with separate DRC-01s and ARNs for each year. Due to a time-bar issue, the ARN for the year 2017-18 was verified, and an order was passed for 2017-18 with DRC-07 under Section 74. How should the remaining cases for the years 2018-19, 2019-20, 2020-21, and 2021-22 be proceeded with? Is it possible to change the notice issued under Section 74 to Section 73? The Hon ble High Court has directed consideration of the petitioner s submission that there was no just cause or reason to invoke the provisions of Section 74 of the CGST/SGST Acts for the years 2018-19 to 2021-22 because the dealer remitted the complete tax amount after obtaining the show cause notice. The case was invoked due to a difference in the tax rate, i.e., 5% instead of 12%. In this scenario, can Section 74 be changed to Section 73?