Index of Relevent Files CGST Section 73

TIME LIMIT TO ISSUE NOTICE & ORDER U/S 73

Period	Due Date to Issue Notice (2 years and 9 months from due dates to pass order or any extended period)	Due/ Extended Date to Pass an Order (3 years from the due date of GSTR-9)	States/Districts
2017-18	30.09.2023	31.12.2023 (NN 09/2023)	For all states
2018-19	31.01.2024	30.04.2024 (NN56/2023)	For all states
2019-20	31.05.2024	31.08.2024 (NN 56/2023)	For all states
2020-21	30.11.2024	28.02.2025	For all states
2021-22	30.09.2025	31.12.2025	For all states
2022-23	10.10.2026	10.01.2027	Chennai, Tiruvallur, Chengalpattu, Kancheepuram, Tirunelveli, Tenkasi, Kanyakumari, Thoothukudi and Virudhunagar in the state of Tamil Nadu
2022-23	30.09.2026	31.12.2026	For all states
2023-24	30.09.2027	31.12.2027	For all states

COMMUNITY INSIGHTS

Topic		Publish Date
	No More 'We Didn't Know": Allahabad HC's Rajdhani Udyog Order Slaps Personal Costs on GST Officer and Demands a System to Keep Officers Updated On 25 August 2025, the Allahabad High Court, in M/s Rajdhani Udyog v. State of U.P. 2025(08)LCX0381- (Writ Tax No. 3684 of 2025), delivered a pointed message to the tax administration: ignoring binding precedent is not a harmless lapse-it is a breach of judicial discipline with personal consequences. Taking note that an appellate authority had failed to apply controlling decisions already on the books, the Court (Piyush Agrawal, J.)...... Read More	24.09.2025
	Notice to Notice-Givers: Courts Won't Tolerate Defective SCNs A show-cause notice (SCN) is not a mere formality. It is the legal foundation of adjudication under Sections 73/74 of the CGST/SGST Acts. If the foundation is cracked-vague allegations, wrong dates, no hearing-the entire superstructure (order, recovery, even bank garnishee) collapses. Recent High Court rulings have made this abundantly clear, most recently in Reynard Corporate Solutions Pvt. Ltd. v. State of U.P. 2025(08)LCX0196,....... Read More	01.09.2025
	Justice Speaks Through Reasons: The Supreme Court’s Guiding Light for GST Adjudication In Indian jurisprudence, the principle of natural justice is not a mere procedural formality—it is the moral backbone of fairness, transparency, and accountability in governance. Among its cardinal components is the duty to record reasons for any decision affecting the rights, liabilities, or interests of an individual. This duty is not confined to the judiciary. It extends to quasi-judicial authorities, tribunals,.......... Read More	08.08.2025
	A Breakdown of DRC Forms: Understanding Their Role in GST Demand and Recovery Received a GST notice and unsure what it means? The DRC forms play a crucial role in tax demand, recovery, and compliance under the GST regime. Understanding these forms is essential for taxpayers to respond correctly and avoid unnecessary penalties. The GST law provides a structured mechanism for tax authorities to communicate with taxpayers regarding tax demands, discrepancies, interest, penalties, and recoveries......................... Read More	28.02.2025
	Unmasking the Fraud: How to Spot and Verify Fake GST Notices Received a GST violation notice? Hold on before you panic-it might not be real. Recently, scammers have ramped up their game by sending fake GST summons that look alarmingly official. These fraudulent notices are designed to trick taxpayers into acting fast-demanding payments or personal information, all while mimicking the real thing. If you've been targeted by one of these scams, you're not alone. The Central Board of Indirect Taxes and Customs....................... Read More	19.02.2025
	Demand Order not Uploaded on Common Portal is Valid or Invalid For initiating the recovery proceedings against the taxable person there is a proper mechanism for serving show cause notices and orders. The same is contained in section 73, 74 and 74A of CGST Act 2017. Where it appears to the proper officer that any tax has not been paid or short paid or erroneously refunded, or where the ITC has been wrongly availed or utilised, then he shall serve a show cause notice (SCN) to the person chargeable with tax.................. Read More	18.12.2024

NOTIFICATIONS

Notification No.	Subject
Notification No. 56/2023 - Central Tax dt. 28.12.2023	Seeks to extend dates of specified compliances in exercise of powers under section 168A of CGST Act

PORTAL RELATED UPDATES

Date	Subject
26/09/2024	Advisory on issuance of Notices/Orders without digital signatures of the issuing authorities

CIRCULARS

Circular No.	Subject
Circular No. 249/06/2025-GST dt. 09.06.2025	Generation and quoting of Document Identification Number (DIN) on any communication issued by the officers of the Central Board of Indirect Taxes and Customs (CBIC) to tax payers and other concerned persons
Circular No. 239/33/2024-GST dt. 04.12.2024	Amendment to Circular No. 31/05/2018-GST, dated 9th February, 2018 on 'Proper officer under sections 73 and 74 of the Central Goods and Services Tax Act, 2017 and under the Integrated Goods and Services Tax Act, 2017'
Circular No. 238/32/2024-GST dt. 15.10.2024	Clarification of various doubts related to Section 128A of the CGST Act, 2017.
Circular No. 237/31/2024-GST dt.15.10.2024 [Para 3]	Clarifying the issues regarding implementation of provisions of sub-section (5) and sub-section (6) in section 16 of CGST Act, 2017.
Circular No. 185/17/2022-GST dt. 27.12.2022	Clarification with regard to applicability of provisions of section 75(2) of Central Goods and Services Tax Act, 2017 and its effect on limitation
Circular No. 171/03/2022-GST dt. 06.07.2022 [Para 1 (1)]	Clarification on various issues relating to applicability of demand and penalty provisions under the Central Goods and Services Tax Act, 2017 in respect of transactions involving fake invoices.
Circular No.169/01/2022-GST dt. 12.03.2022	Amendment to Circular No. 31/05/2018-GST, dated 9th February, 2018 on ‘Proper officer under sections 73 and 74 of the Central Goods and Services Tax Act, 2017 and under the Integrated Goods and Services Tax Act, 2017
Circular No.128/47/2019-GST dt. 23.12.2019	Generation and quoting of Document Identification Number (DIN) on any communication issued by the officers of the Central Board of Indirect Taxes and Customs (CBIC) to tax payers and other concerned persons
Circular No. 122/41/2019-GST dt. 05.11.2019	Generation and quoting of Document Identification Number (DIN) on any communication issued by the officers of the Central Board of Indirect Taxes and Customs (CBIC) to tax payers and other concerned persons
Circular No. 76/50/2018-GST dt. 31.12.2018 [Para 2]	Clarification on certain issues (sale by government departments to unregistered person; leviability of penalty under section 73(11) of the CGST Act; rate of tax in case of debit notes / credit notes issued under section 142(2) of the CGST Act; applicability of notification No. 50/2018-Central Tax; valuation methodology in case of TCS under Income Tax Act and definition of owner of goods) related to GST
Circular No. 31/5/2018-GST dt. 09-02-2018	Proper officer under sections 73 and 74 of the Central Goods and Services Tax Act, 2017 and under the Integrated Goods and Services Tax Act, 2017

INSTRUCTIONS

Instruction No.	Subject
Instruction No. 02/2025-GST dt. 07.02.2025	Procedure to be followed in department appeal filed against interest and/or penalty only, related to Section 128A of the CGST Act, 2017
Instruction No. 04/2023-GST dt. 23.11.2023	Serving of the summary of notice in FORM GST DRC-01 and uploading of summary of order in FORM GST DRC-07 electronically on the portal by the proper officer
Instruction No. 02/2021-22 dt. 22.09.2021 [GST-Investigation]	Issuance of SCNs in time bound manner

ORDERS

Order No.	Subject
Order No. 2/2019-GST dt. 12.03.2019	Appointment of common authority for the purpose of exercise of powers under sections 73,74, 75 and 76 of the CGST Act, 2017

CASE LAWS

Authority	One liner
2025(10)LCX0006 Telangana High Court Sri Venkatesh Fibre Corporation	Section 73 order dated 01.05.2024 is beyond the extended deadline (30.04.2024) and hence void for limitation.
2025(08)LCX0209 Allahabad High Court Venus Trading Co	Any adjudication under section 73 against a deceased person is void; notice must issue to the legal representative.
2025(08)LCX0196 Allahabad High Court Reynard Corporate Solutions Private Limited	Personal hearing cannot precede the reply deadline; a defective SCN vitiates proceedings—order quashed with liberty to issue a fresh SCN.
2025(08)LCX0164 Delhi High Court Raghunath Enterprises	Consolidated SCNs spanning multiple years are valid in fraudulent ITC matters; remedy lies in statutory appeal, not writ.
2025(08)LCX0065 Delhi High Court Hind Paper House	DRC-01 without RUDs is procedurally deficient, but once service is proved, the remedy is remand for de novo hearing, not outright quashment on merits.
2025(07)LCX0381 Allahabad High Court O S R International	Ex parte GST orders against deregistered entities are invalid if notice is not properly served by alternative means.
2025(07)LCX0209 Madras High Court R Ashaarajaa	Bunching multiple financial years into one GST show-cause notice is statutorily impermissible.
2025(07)LCX0204 Bombay High Court Nuvoco Vistas Corporation	Courts will not interfere with show cause notices unless jurisdictional error is evident on the face.
2025(07)LCX0195 Allahabad High Court SREI Equipment Finance Limited	Tax authorities cannot enforce pre-CIRP claims post-approval of the Resolution Plan under IBC.
2025(07)LCX0147 Madras High Court Agri Tech Corporation	Assessment orders violating natural justice and lacking clear procedural compliance must be re-adjudicated on terms.
2025(07)LCX0096 Allahabad High Court Tripureshwari Traders	GST notices must be served through alternative means once registration is cancelled; portal upload alone is insufficient.
2025(07)LCX0086 Allahabad High Court Lalaram Thekedar	Service of notice solely via portal post-registration cancellation violates natural justice.
2025(07)LCX0084 Andhra Pradesh High Court Godavari Polymers Private Limited	Absence of DIN and signature in GST orders renders them void and unenforceable
2025(07)LCX0037 Calcutta High Court Hotel Rudra	Ex parte orders without hearing violate natural justice and warrant remand for fresh adjudication.
2025(06)LCX0484 Madras High Court Tvl Saravanan	Assessment orders passed without proper hearing or by circumventing limitation can be quashed with an opportunity for compliance.
2025(06)LCX0475 Madras High Court Tata Play Limited	Section 168A empowers the Government to extend statutory timelines during extraordinary circumstances; notifications issued thereunder are valid.
2025(06)LCX0453 Madras High Court Tvl SKP Readymix	Assessment orders must reflect application of mind and deal with taxpayers replies through reasoned discussion.
2025(06)LCX0452 Madras High Court Boldrocchi India Pvt. Ltd.	Manual replies must be considered by tax authorities; ignoring them violates natural justice.
2025(06)LCX0400 Gauhati High Court Mahabir Tiwari	Notification No. 56/2023-Central Tax is ultra vires due to the absence of GST Council recommendation and force majeure conditions, rendering subsequent actions invalid.
2025(06)LCX0319 Gauhati High Court Biswa Ranjan Borah	Summary notices without proper show cause and hearing violate Sections 73 and 75(4) of CGST Act.
2025(06)LCX0311 Allahabad High Court F K Fancy Zari Art	Mere reproduction of a GST notice without reasoning violates Section 75(6) and renders the order invalid.
2025(06)LCX0302 Madras High Court Tvl Leto	Portal-only service without exploring alternate modes under Section 169 violates natural justice.
2025(05)LCX0583 Delhi High Court Shashi Kumar Choudhary	No tax or penalty can be enforced without issuance of a Show Cause Notice and due adjudication under GST law.
2025(05)LCX0563 Delhi High Court Ganpati Exports Private Limited	Duplicated and erroneous ITC demands must be rectified before enforcing adjudication.
2025(05)LCX0146 Allahabad High Court Janta Machine Tools	Tax demand for excess stock must follow Section 73/74, not Section 130 of GST Act
2025(04)LCX0561 Kerala High Court Tharayil Medicals	Separate show cause notices must be issued for each assessment year under Section 74 CGST/SGST Act.
2025(04)LCX0430 Madras High Court Indian Railway Finance Corporation Limited	Natural justice mandates that new grounds in tax orders must be preceded by due notice and hearing.
2025(04)LCX0167 Kerala High Court Mjbr Marketing And Financial Services Private Limited	CBIC Circular No.192/04/2023 held that electronic credit ledger must be treated as a unified pool of funds across tax heads, where CGST, SGST, and IGST credits are considered as separate compartments of one wallet
2025(04)LCX0152 Allahabad High Court Gupta Traders	Demand order u/s 73 of the UP GST Act is quashed as time-barred, as orders for FY 2017–18 issued after 05.02.2023 were beyond the statutory limit
2025(03)LCX0377 Delhi High Court Neelgiri Machinery	Orders passed and uploaded under "Additional Notices and Orders," tab making less directly visible were set aside in view of ensuring compliance with principles of natural justice and importance of proper communication and accessibility of notices
2025(03)LCX0140 Kolkata Tribunal Raza International	Commissioner (Appeals) is obligated to pass a detailed ex-parte order after reviewing the importer Statement of Facts and Grounds of Appeal, regardless of the importer presence at the hearing.
2025(03)LCX0007 Kolkata Tribunal Asha Enterprises	Non challenging of the assessment order is deemed to attain finality and initiation of any subsequent proceedings against such order is erroneous
2025(03)LCX0001 Bombay High Court Precaution Properties Private Limited	Court granted interim relief against coercive action u/s 73 of the CGST Act, pending the SC's decision on the validity of N/No. 9/2023-CT & 56/2023-CT issued without GST Council recommendations
2025(02)LCX0191 Allahabad High Court Anita Traders	Considering the fact that notification dated 24.04.2023 extending time limit for passing of an order u/s 73(9) is not applicable in case of Assessment Order passed on 02.12.2023, the same is set aside.
2025(02)LCX0315 Supreme court of India Hcc-Sew-Meil-Aag JV	Matter regarding validity of extension of time limit for adjudication of show cause notice and passing order under Section 73 of the GST is pending.
2025(02)LCX0129 Telangana High Court Bigleap Technologies and Solutions Private Limited	Unsigned show-cause notices and final orders under GST even when uploaded online are invalid because the signature column in the prescribed forms constitutes a mandatory statutory requirement for authenticity.
2025(01)LCX0426 Madras High Court Tvl V K D Stores	Assessment order issued u/s 73 GST Act set aside as assessee was unaware of the proceedings due to the notices being uploaded on the GST portal instead of being properly served
2025(01)LCX0425 Madras High Court Tvl Jainsons Castors and Industrial Products	Assessment order issued u/s 73 GST Act set aside as assessee was unaware of the proceedings due to the notices being uploaded on the GST portal instead of being properly served
2025(01)LCX0033 Chandigarh Tribunal Iffco Tokio Insurance Services Limited	Cenvat credit cannot be denied due to procedural irregularities
2025(01)LCX0015 Telangana High Court Brunda Infra Private Limited	GST notification extensions of limitation periods due to COVID-19 were upheld relying on a Supreme Court order excluding a specific period for limitation rendering challenges to the notifications academic while also noting the assessee availability of statutory appeals.
2024(12)LCX0478 Gauhati High Court Rosida Sultana	Issuance of the Summary of the SCN, Summary of the Statement and Summary of the Order do not dispense with the requirement of issuance of a proper SCN and Statement as well as passing of the Order as per the mandate of Section 73 of CGST Act by the Proper Officer.
2024(11)LCX0379 Allahabad High Court A V Pharma	Orders issued by the Deputy Commissionerare quashed for beyond the time limit prescribed U/S73and assessee bank accounts is to be de-freezed
2024(11)LCX0039 Bombay High Court Esjapee Impex (P) Ltd.	Adjudicating Authority should have adjudicated the SCN within a reasonable time; failure to do so is bound to cause prejudice to the assessee.
2024(11)LCX0012 Allahabad High Court Ashish Traders	Assessee is entitled to the benefit of doubt when Notice not been uploaded on the Due Notices and Orders and instead uploaded on Additional Notices and Orders
2024(10)LCX0143 Gauhati High Court Udit Tibrewal	Non-issuance of a proper and prior SCN, as contemplated u/s 73(1) of GST Act and issuance of only Summary of SCN and Attachment to Determination of Tax cannot be said to be in compliance with Section 73(1) read with rule 142(1), a Summary of SCN is held to be not a substitute of a SCN.
2024(09)LCX0571 Allahabad High Court Wonder Enterprises	Passing an appellate order on a date later than the hearing without statutory backing violates GST procedural fairness.
2024(09)LCX0567 Karnataka High Court Jagadish Advertising	Extended limitation under Section 73 cannot be invoked without specific, substantiated allegations of fraud or suppression.
2024(09)LCX0243 Karnataka High Court Veremax Technologie Services Limited	Consolidated SCN for multiple tax years contravenes the provisions of the CGST Act as separate notices are required for each assessment year.
2024(08)LCX0387 Karnataka High Court Bangalore Golf Club	Court quashed the consolidated SCNs for multiple tax periods under the CGST Act and ruled that each assessment year must be independently assessed.
2024(07)LCX0558 Calcutta High Court Natraj Electro Casting Private Limited	Recovery stayed where adjudication exceeded show cause notice and appellate remedy was illusory due to absence of Tribunal.
2024(05)LCX0330 Allahabad High Court Graziano Trasmissioni	Extension N/No. 09/2023 u/s 168A for adjudicating proceedings for the FY 2017-18 is valid.
2024(05)LCX0274 Delhi High Court Mitchem Impex	Proper officer could not have adjudicated the SCN prior to the stipulated date for filing response.
2024(04)LCX0206 Delhi High Court AB Traders	Proper officer cannot held that the reply is unsatisfactory without considering the reply and enclosed documents
2024(02)LCX0560 Allahabad High Court Katyal Industries	GST cacnellation order is set aside due to non-compliance with natural justice assessee to treat order as notice and respond within 4 weeks.
2024(02)LCX0425 Delhi High Court Aarem TradEx Private Limited	Proper officer need to at least consider the reply on merits before forming an opinion whether the explanation of assessee was sufficient or not.
2024(02)LCX0423 Delhi High Court Emco Cables (India) Private Limited	Proper officer need to at least consider the reply on merits before forming an opinion whether the explanation of assessee was sufficient or not.
2024(01)LCX0498 Allahabad High Court Khanna Polyrib Private Limited	Assessee's right to object to the SCN and participate in the personal hearing cannot be comprised if SCN had been served without all its contents and annexures
2023(12)LCX0304 Madras High Court Titan Company Ltd.	Where an assessment encompasses different assessment years, each assessment year could be easily split up and dissected and the items can be separated and taxed for different periods.
2023(11)LCX0167 Madhya Pradesh High Court Raymond Ltd	Show cause notice falls short of the minimum period to afford reasonable opportunity and also lacking in material particular, thereby set aside.
2023(10)LCX0105 Kerala High Court Global Plasto Wares	GST: Penalty leviable when tax collected is not deposited within 30 days
2021(07)LCX0205 Allahabad High Court V.S. Enterprises	Multiple overlapping GST orders for same period are invalid; fresh adjudication must follow due process.
2021(02)LCX0096 Jharkhand High Court R.P.M. Distributors	For delayed payment of tax, the interest would be levied on net tax liability.
2021(01)LCX0284 Patna High Court Pinax Steel Industries Pvt. Ltd	Order passed without hearing violated natural justice; matter remanded for fresh adjudication after proper opportunity.
2019(06)LCX0002 Patna High Court Commercial Steel Engineering Corporation	Court allowed transitional credit for FY 2007-08 and 2011-12 which was not reflected in prior returns due to Accountant's mistake
2019(03)LCX0033 Rajasthan High Court Leel Electricals Limited	Court is not convinced by arguments advanced by petitioner, therfore notice of summon is not quashed