This discussion clarifies the time limits for issuing GST notices for the financial year 2019-20. For Section 73 of the CGST Act, the last date to issue a show-cause notice was 31 May 2024. For Section 74, which deals with cases of fraud or wilful misstatement, the notice must be issued within 6 months before the expiry of 5 years from the annual return's due date, placing the deadline around 30 September 2025.
09 September 2025
For the financial year 2019-20, the limitation period for issuing a notice under Section 74 of the GST Act is "6 months before the expiry of 5 years from the due date of filing the annual return" for that year. it means Last date for notice issuance: 6 months prior = 30 September 2025 as.. Last date for order issuance: 5 years from this due date = 31 March 2026.
A notice under Section 74 of the GST Act is issued when the department believes that tax has not been paid, has been short paid, input tax credit has been wrongly availed or utilized, or there is an erroneous refund—all due to fraud, willful misstatement, or suppression of facts.