The proper officer shall serve notice under the provisions of Section 73(1) along with a summary, electronically in Form GST DRC-01 (as per Chapter XVIII-Demands and Recovery of the CGST Rules) on the person chargeable with tax for any reason other than:
fraud
willful misstatement
suppression of facts,
when he has reasons to believe that tax has not been paid or short paid or erroneously refunded or input tax credit has been wrongly availed or utilized.
(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 for any reason other than fraud or any willful misstatement or suppression of facts: FAQ NO. 1)