The proper officer shall serve notice under the provisions of Section 74(1) along with a summary electronically in Form GST DRC-01 on the person chargeable with tax for any reason of :
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 by reason of fraud or any willful misstatement or suppression of facts : FAQ NO. 9)