2025 (8) TMI 1446

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....r>Honourable Mr.Justice C.Saravanan For the Petitioner : Mr.N.Sudalai Muthu For the R1 & R2 : Mr.R.Suresh Kumar Additional Government Pleader For the R3 : Mr.K.Govindarajan Deputy Solicitor General of India COMMON ORDER The petitioner is before this Court challenging the respective impugned assessment orders dated 25.11.2023 and 26.12.2023 for the assessment years 2017- 2018 and 201....

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....h certain directions. The operative portion of the said order reads as under: "10. Conclusion: i) The authorities under the CGST Act shall have the benefit of exclusion of the period 15.03.2020 to 28.02.2022, while reckoning limitation under sub section (2) and (10) to Section 73 of CGST Act, in terms of the of the Supreme Court dated 10.01.2022 passed under Article 142 of the Co....

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....s under CGST Act by diminishing the limitation thus suffers from the vice of arbitrariness. d) The impugned notification is issued on the basis of recommendation made without examining relevant materials discussed supra and thus stands vitiated. e) In addition to the above reasons, impugned notification No.56/2023 is made even prior to the recommendations of the GST Council, fail....