GST limitation notifications under Section 168A were held unsustainable, leading to quashing of assessment orders and remand.

Notifications issued under Section 168A of the GST enactments were treated as unsustainable, and the limitation period was required to be reckoned in the manner indicated by the Supreme Court's Article 142 order. On that basis, the impugned assessment orders could not be sustained. The respondents were nevertheless left free to proceed further in accordance with law and the interim order referred to in the judgment, and the matters were remitted for fresh consideration on merits.

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Issues: Whether the impugned assessment orders were liable to be quashed in view of the challenge to the notifications issued under Section 168A of the Goods and Services Tax enactments, and whether the matters should be remitted for fresh consideration on merits.

Analysis: The assessment orders were passed after a significant delay and the petitioner had not responded to the pre-assessment notices. The Court, however, followed the earlier binding view that the notifications issued under Section 168A were unsustainable and that the limitation period had to be reckoned in the manner indicated by the Supreme Court's order under Article 142 of the Constitution of India. In that light, the impugned assessment orders could not be sustained. At the same time, the respondents were left free to proceed further in accordance with law and in the light of the interim order of the Supreme Court referred to in the judgment.

Conclusion: The impugned assessment orders were quashed and the matters were remitted to the respondents to pass fresh orders on merits.

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