GST limitation under Section 168A and Section 73(10) controls adjudication timelines; time-barred order quashed.

An adjudication order passed beyond the limitation prescribed under Section 73(10) of the CGST Act and Assam GST Act is without jurisdiction where no valid notification under Section 168A extends time. The record showed no such extension beyond 30.04.2024 for the relevant financial year, while the order was made on 04.05.2024. It was therefore held to be time-barred, without jurisdiction, and set aside.

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Issues: Whether the order-in-original passed on 04.05.2024 under the Central Goods and Services Tax Act, 2017 and the Assam Goods and Services Tax Act, 2017 was barred by limitation and therefore without jurisdiction in the absence of a notification extending the time under Section 168A.

Analysis: The order was required to be passed within the period prescribed under Section 73(10) of the Central Goods and Services Tax Act, 2017 and the Assam Goods and Services Tax Act, 2017 for the financial year 2018-19. The record disclosed no notification under Section 168A of either enactment extending the period beyond 30.04.2024. Since the impugned order was passed on 04.05.2024, it fell beyond the statutory time limit.

Conclusion: The impugned order was beyond limitation and without jurisdiction, and it was set aside and quashed.

Ratio Decidendi: In the absence of a valid notification extending time under Section 168A, an adjudication order passed beyond the limitation prescribed under Section 73(10) is jurisdiction and liable to be quashed.

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