Condonation of Delay: Tribunal directed condonation where rectification proceedings were pursued, ordering merits adjudication after opportunity to be...
Restriction of Input Tax Credit under Rule 86A applies only to fraudulently or ineligible availed credit; mere wrongful recipient availment is insuffi...
The note addresses validity of a single show cause notice aggregating multiple financial years under the CGST Act: each financial year is a distinct tax period with separate limitation periods under Sections 73(10) and 74(10), so limitation runs year by year and notices must respect that structure; allegation of fraudulent availment of input tax credit permits only application of any extended limitation provided by law but does not authorise clubbing of different years into one notice. Consequence: a consolidated multi year notice is invalid to the extent of aggregation, but respondents may reissue year wise notices complying with the statutory limitation regime.
The note addresses validity of a single show cause notice aggregating multiple financial years under the CGST Act: each financial year is a distinct tax period with separate limitation periods under Sections 73(10) and 74(10), so limitation runs year by year and notices must respect that structure; allegation of fraudulent availment of input tax credit permits only application of any extended limitation provided by law but does not authorise clubbing of different years into one notice. Consequence: a consolidated multi year notice is invalid to the extent of aggregation, but respondents may reissue year wise notices complying with the statutory limitation regime.
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