Limitation under GST adjudication renders delayed demand and bank attachment void when the order is passed beyond the extended period.

An adjudication order under section 73 of the Telangana GST Act passed after the statutorily extended period was time-barred and therefore void. As the order-in-original and Form GST DRC-07 summary were both issued on 01.05.2024, after the extended deadline of 30.04.2024, they were quashed. The consequential bank attachment could not survive because it was founded on an invalid adjudication order and was also set aside.

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Issues: Whether the order-in-original and consequential demand summary passed under section 73 of the Telangana Goods and Services Tax Act, 2017 were barred by limitation and liable to be set aside, and whether the consequential bank attachment could survive.

Analysis: For the relevant financial year, the time for passing the order stood extended up to 30.04.2024 by the applicable CBIC circular and the corresponding State notification. The impugned order-in-original and the Form GST DRC-07 summary were both dated 01.05.2024, i.e. beyond the permissible period. Since the foundational adjudication order itself was time-barred, the consequential attachment issued pursuant thereto could not stand.

Conclusion: The order-in-original, the summary in Form GST DRC-07, and the consequential bank attachment were quashed as barred by limitation.

Final Conclusion: The writ petition succeeded and the impugned tax recovery action was annulled on the ground of limitation.

Ratio Decidendi: An adjudication order under section 73 passed beyond the statutorily extended period is void for limitation, and all consequential recovery measures founded on such an order must fall.

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