Daily Archives: June 8, 2026

Appellate Limitation Runs From Declared Date of Communication Unless Revenue Rebuts With Cogent Evidence Issue Whether the statutory limitation period for filing a first appeal under Section 107 of the CGST/SGST Act begins from the date of the actual communication of the adjudication order as declared by the assessee, and whether the burden rests on… Read More »

Consolidated Show Cause Notice Covering Six Financial Years Quashed as Legally Unsustainable Under Section 73 Issue Whether the tax authorities have the jurisdiction under Section 73 of the CGST/SGST Act to issue a single, consolidated Show Cause Notice (SCN) spanning six consecutive financial years (FY 2019-20 to 2024-25), or if the statutory scheme mandates the… Read More »

Demand Provision Cannot Be Used as Short Cut to Bypass Review and Appeal Against Refund Sanction Orders Demand Provision Cannot Be Used as Short Cut to Bypass Review and Appeal Against Refund Sanction Orders Issue Whether the tax authorities are legally permitted to invoke the demand provisions under Section 73 to nullify a previously sanctioned… Read More »

General Penalty Under Section 125 Cannot Be Levied for Non Filing When Specific Late Fee Is Prescribed Issue Whether the tax authorities are legally justified in imposing a general penalty under Section 125 of the CGST/SGST Act in addition to a late fee under Section 47 for the non-filing of GST returns, and whether a… Read More »