GST extension notifications under challenge, with interim protection granted against coercive action on the assessment order.

A challenge was raised to notifications extending the time limit under Section 168A of the CGST Act on the ground that they were not issued on the GST Council's recommendation, with a further contention that the assessment order under Section 73(9) would fail if those notifications were invalid. The Court noted that the validity of the extension notifications was already under consideration in a connected Supreme Court matter. On the interim prayer, it found a strong prima facie case for protection against coercive action, as the impugned order may have been passed beyond the extended period. Rule was issued and interim relief granted restraining further action pursuant to the order.

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Issues: Whether the notifications extending time limits under Section 168A of the Central Goods and Services Tax Act, 2017 were valid and, pending adjudication, whether coercive steps could be taken in pursuance of the assessment order passed under Section 73(9) of that Act.

Analysis: The petition raised an arguable challenge that the later extension notifications were not issued on the recommendation of the GST Council, and that the impugned order would fall if those notifications were invalidated. The order also noted that the validity of the notifications was the subject of proceedings before the Supreme Court in a connected matter. On the interim prayer, the Court found a strong prima facie case for protection against coercive action, having regard to the validity challenge and the possibility that the impugned order was passed beyond the extended period.

Outcome: Rule issued. Interim relief was granted restraining further action pursuant to the impugned order.

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