GST time-limit extension notifications face challenge as interim protection is granted against action on the assessment order.

Notifications issued under Section 168A extending CGST time limits were challenged as lacking recommendation of the GST Council, and the Court treated the legality of those extension notifications as an arguable issue. It also noted that similar questions were pending before the Supreme Court. On interim protection, the Court found a strong prima facie case because the validity of the notifications directly affected whether the impugned Section 73(9) order could be acted upon. Rule was issued and interim relief was granted restraining further action pursuant to the order.

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Issues: (i) whether the notifications issued under Section 168A extending the time limits under the CGST framework were amenable to challenge on the ground that the subsequent notifications were not issued on the recommendation of the GST Council; and (ii) whether interim protection should be granted against acting upon the impugned order passed under Section 73(9) of the CGST Act.

Analysis: The challenge was treated as raising arguable questions, including the legality of the extension notifications and their asserted non-compliance with the requirement of recommendation of the GST Council. The Court also noted that similar issues were pending consideration in proceedings before the Supreme Court. On interim relief, the Court found a strong prima facie case for protection, particularly since the validity of the notifications had a direct bearing on whether the impugned order could be acted upon.

Outcome: Rule was issued and interim relief was granted restraining the respondents from acting upon or taking further steps in pursuance of the impugned order.

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