https://www.taxtmi.com/article/detailed?id=14940 Limitation for issuance of show cause notices under Section 73(2) of the CGST Act must be construed by calendar month computation rather than as a fixed 90 day period, with the phrase "three calendar months" requiring counting the same date across successive calendar months. Applying that approach to a reference date for passing an order on the annual return yields a window that includes an SCN issued on November 30 when counted back from the due date of February 28. The Court noted that, even under a day count approach, the interval equaled the 90 day span, so the notice was not time barred. en-us Mon, 11 Aug 2025 08:43:57 +0530 Mon, 11 Aug 2025 08:43:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/article/detailed?id=14940 Limitation for issuance of show cause notices under Section 73(2) of the CGST Act must be construed by calendar month computation rather than as a fixed 90 day period, with the phrase "three calendar months" requiring counting the same date across successive calendar months. Applying that approach to a reference date for passing an order on the annual return yields a window that includes an SCN issued on November 30 when counted back from the due date of February 28. The Court noted that, even under a day count approach, the interval equaled the 90 day span, so the notice was not time barred. Articles Goods and Services Tax - GST Mon, 11 Aug 2025 08:43:57 +0530 https://www.taxtmi.com/article/detailed?id=14940