GST Audit - Time Bar on Show Cause Notice

[VAISHACH Vaishach]

Hello Expert 

My father"s company was recently audited for FY 2017-18 to FY 2023-24. The Audit was conducted in the First week of June and Form GST ADT-02 was issued and audit findings are issued. I also intend to furnish my reply for the Audit Report accepting a few things on our part and also wanting to contest a few things.

We want to go for an appeal on the same. In the Audit Report, after each para it is given, you are liable to pay as per Section 73 and Section 50 of the GST Act. 

My question is

1. What is the next step after my reply has been furnished? 

2. Assuming there is no Fraud or Willful suppression, will SCN be issued based on Section 73 of the Act?

3. If yes, isn"t it time barred.. Do i have any remedy to contest the time bar for GST Audit also

AI Summary

Time bar for GST tax demands can preclude ordinary notices, while fraud invocation may extend initiation and shift the burden of proof.
After issuance of Form GST ADT-02, audit observations move to adjudication via departmental notices, with an opportunity to reply before a final demand order and appeals. Ordinary tax demands are subject to limitation and will be time barred where the statutory period has expired; invocation of the fraud provision allows initiation beyond ordinary limitation but places the burden of proof on the department. Practical disputes include reverse charge liabilities and the recoverability of interest when the underlying tax demand is time barred.