Section 73's three-month minimum period for issuing a GST show-cause notice before the deadline for an order is mandatory and preserves a meaningful opportunity to respond. Extension of the outer time limit for the order does not extend the deadline for issuing notice unless the statute provides otherwise. A notice created only in an internal system, awaiting GSTN confirmation and lacking a CRN, is not issued or served where it is neither integrated with the common portal nor otherwise communicated to the taxpayer. Later portal upload cannot retrospectively cure limitation; scrutiny communications and hearing opportunities cannot replace a foundational notice.
Section 73's three-month minimum period for issuing a GST show-cause notice before the deadline for an order is mandatory and preserves a meaningful opportunity to respond. Extension of the outer time limit for the order does not extend the deadline for issuing notice unless the statute provides otherwise. A notice created only in an internal system, awaiting GSTN confirmation and lacking a CRN, is not issued or served where it is neither integrated with the common portal nor otherwise communicated to the taxpayer. Later portal upload cannot retrospectively cure limitation; scrutiny communications and hearing opportunities cannot replace a foundational notice.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
