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<h1>Tax Assessment Invalidated: Administrative Order Exceeds Limitation Period Under GST Legislation, Rendering Order Void</h1> The SC examined a tax dispute involving GST legislation and found the administrative order was issued beyond the prescribed limitation period. The court ... Time-bar for issuance of order under Section 73(10) of the Central and State Goods and Services Tax Acts - jurisdictional effect of issuing assessment order after expiry of limitation - extension of limitation by notification under Section 168A of the Central and State Goods and Services Tax Acts - validity of order passed under Section 73(9) of the Central and State Goods and Services Tax ActsTime-bar for issuance of order under Section 73(10) of the Central and State Goods and Services Tax Acts - extension of limitation by notification under Section 168A of the Central and State Goods and Services Tax Acts - validity of order passed under Section 73(9) of the Central and State Goods and Services Tax Acts - jurisdictional effect of issuing assessment order after expiry of limitation - Whether the order dated 04.05.2024 passed under Section 73(9) for the financial year 2018-19 was time barred and without jurisdiction in the absence of any notification extending the limitation under Section 168A. - HELD THAT: - The Court noted that Section 73(10) prescribes that the order must be passed within three years from the due date of filing of the annual returns for the relevant year. For the financial year 2018-19, no notification under Section 168A of either the Central Act or the State Act had been issued to extend the period for passing orders beyond 30.04.2024. As the impugned order was dated 04.05.2024, it was passed after the limitation period and in the absence of any statutory extension. The Court held that an assessment order passed beyond the prescribed period, without a valid extension by notification, is beyond jurisdiction and cannot be sustained.Impugned order dated 04.05.2024 set aside as time barred and without jurisdiction.Final Conclusion: The petition succeeds; the assessment order dated 04.05.2024 for financial year 2018-19 is quashed for being barred by limitation in the absence of any extension notification under Section 168A, and the writ petition is disposed of. The petitioner challenged an order passed under the Central Goods and Services Tax Act and the Assam Goods and Services Tax Act, claiming it was beyond the limitation period. The court found that the order was indeed passed beyond the deadline and set it aside, ruling it as without jurisdiction. The writ petition was disposed of accordingly.
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