TaxTMI 
TaxTMI 
As per S. 73, notice is to be issued 3 months prior to order.
For FY20-21, the last date to issue order u/s 73 is 28.02.2025.
View above, what is the last date for SCN. is it 30.11.2024 or 28.11.2024 ?
SCN due date S. 73
04 Dec 2024 
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Limitation period calculation: whether 'prior to' excludes the terminal date or is inclusive under general clauses.
The deadline for issuing a show-cause notice under Section 73 CGST is disputed: some practitioners apply the General Clauses Act, 1897 to read "prior to" as inclusive of the terminal date when computing a three-month period, while others apply calendar-month reckoning and exclude the terminal date. The correspondence cites case law and warns that reliance on procedural invalidity alone is risky, recommending preservation of merits defences and, where appropriate, writ remedies. (AI Summary)
The deadline for issuing a show-cause notice under Section 73 CGST is disputed: some practitioners apply the General Clauses Act, 1897 to read "prior to" as inclusive of the terminal date when computing a three-month period, while others apply calendar-month reckoning and exclude the terminal date. The correspondence cites case law and warns that reliance on procedural invalidity alone is risky, recommending preservation of merits defences and, where appropriate, writ remedies. (AI Summary)