Limitation in GST adjudication can extinguish jurisdiction, and belated orders passed beyond the statutory cut-off were set aside.

An order-in-original passed under Section 73 of the Telangana GST Act beyond the statutory limitation period for the relevant tax period was treated as without jurisdiction. The explanation of administrative pressure and the taxpayer's later merits submissions did not cure the defect, because limitation went to the very authority to impose tax liability. The appellate order also failed to deal with this jurisdictional bar. On that basis, both the order-in-original and the order-in-appeal were set aside in favour of the assessee.

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Issues: Whether the order-in-original passed under Section 73 of the Telangana Goods and Services Tax Act, 2017 for the tax period April 2019 to March 2020 was barred by limitation and therefore without jurisdiction.

Analysis: The order was dated and uploaded after the statutory cut-off date for passing orders for the relevant tax period. The explanation that the delay occurred because of administrative pressure and the later submissions on merits did not cure the defect, since limitation affected the very authority to impose tax liability. The appellate order also failed to address this jurisdictional defect.

Conclusion: The order-in-original and the order-in-appeal were unsustainable and were set aside. The issue was decided in favour of the assessee.

Ratio Decidendi: An assessment or adjudication order passed beyond the statutory limitation period is without jurisdiction and cannot be sustained, irrespective of subsequent explanations on merits.

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