Where the proper officer is of the opinion that the amount paid under section 74(5) falls short of the actual amount payable, he shall proceed to issue show cause notice under section 74(1) for such shortfall.
(ICAI FAQ PUBLICATIONS 06-09-2017 Determination of tax not paid or short paid or erroneously refunded or input tax credit wrongly availed or utilized by reason of fraud or any willful misstatement or suppression of facts: FAQ NO. 15)