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Issues: Whether the rectification order and rectification show-cause notice issued under Section 161 of the Central Goods and Services Tax Act, 2017 were liable to be quashed as having been passed beyond the prescribed limitation period.
Analysis: Section 161 of the Central Goods and Services Tax Act, 2017 permits rectification of an order within six months from the date of the original order. The impugned rectification order was passed on 27.03.2025, whereas the original order was dated 12.09.2024. The rectification action was therefore taken beyond the statutory period, and the exercise of power under the provision was not sustainable.
Conclusion: The rectification proceedings were held to be time-barred and unsustainable, and the rectification order and connected show-cause notice were quashed.
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