TaxTMI 
TaxTMI 
SIR,
IS THERE ANY TIME LIMIT FOR ISSUING NOTICE U/S 122 OF THE CGST ACT, 2017
TIME LIMIT FOR ISSUE NOTICE U/S 122
05 Apr 2025 
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Goods and Services Tax penalty notices under Section 122 must follow statutory adjudicatory procedures, not rules alone.
Section 122 is a penal provision that does not itself authorize initiation of adjudicatory proceedings or show cause notices; penalties under it must be imposed through the specific statutory adjudicatory mechanisms, and invoking a subordinate rule to bypass those procedures is inconsistent with the Act and therefore ultra vires. (AI Summary)
Section 122 is a penal provision that does not itself authorize initiation of adjudicatory proceedings or show cause notices; penalties under it must be imposed through the specific statutory adjudicatory mechanisms, and invoking a subordinate rule to bypass those procedures is inconsistent with the Act and therefore ultra vires. (AI Summary)