Limitation under CGST Section 73 barred the notice and assessment order where issuance crossed the permissible deadline.

A show cause notice and consequential assessment order under the CGST Act were barred by limitation because, on a combined reading of Section 73(2) and Section 73(10), notice for the 2020-2021 tax period could be issued only up to 28.11.2024. The notice was issued on 30.11.2024, making it time-barred. The Telangana HC followed the reasoning of the Andhra Pradesh HC in the cited decision and held that the impugned assessment order could not be sustained, setting it aside.

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Issues: Whether the show cause notice and the consequential assessment order were barred by limitation under Section 73 of the Central Goods and Services Tax Act, 2017.

Analysis: The tax period was 2020-2021. The assessment order was passed on 28.02.2025, and on a combined reading of Section 73(2) and Section 73(10) of the Central Goods and Services Tax Act, 2017, the notice could have been issued only up to 28.11.2024. Since the notice was issued on 30.11.2024, it fell beyond the permissible period. The reasoning adopted by the Andhra Pradesh High Court in the cited decision was also followed.

Conclusion: The impugned assessment order could not be sustained and was set aside.

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