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2023 (1) TMI 982 - HC - GSTExtension of time limit for issuance of the order - extension of time limit for issuance of show cause notice as well - Section 73 of the CGST/SGST Act - HELD THAT:- It is clear from a reading of sub-section(2) of Section 73 that, the show cause notice to be issued under sub-section(1) of Section 73 has to be issued at least three months prior to the time limit specified in sub-section(10) for issuance of order. When the time limit for issuance order under sub-section(10) of Section 73 for the financial year 2017-18 has been extended upto 30.09.2023, the only interpretation that can be placed on the provisions of sub-section(2) of Section 73 is that, the show cause notice can also be issued with reference to the date 30.09.2023 and not with reference to any other date. There is absolutely no ambiguity in the provisions requiring this Court to apply any rule of interpretation in favour of the assessee. The petitioner has not made out any case for interference under Article 226 of the Constitution of India as it cannot be found that the impugned orders are issued without jurisdiction - petition dismissed.
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