by B Venkateswaran, Retired Asst Commissioner Central GST | GST Consultancy, Training.
Sections 73, 74 and (now) 74A of the CGST Act, 2017 each carry their own countdown for issuance of a Show Cause Notice. Miss tracking one, and either the Department loses its window — or your client is caught unprepared.
A quick snapshot:
→ FY 2020-21 (non-fraud, Sec 73): SCN window already closed on 30-Nov-2024 → FY 2020-21 (fraud, Sec 74): SCN window closes 28-Aug-2026 — days away → FY 2021-22 (non-fraud, Sec 73): SCN window closed 30-Sep-2025 → FY 2022-23 (non-fraud, Sec 73): SCN due by 30-Sep-2026 — approaching → FY 2024-25 onwards: unified Section 74A applies — SCN within 42 months of the GSTR-9 due date, order within 12 months thereafter
Every date above runs from the due date of filing the Annual Return (GSTR-9) for that year — not the financial year-end. A notice issued beyond the statutory limit is open to challenge; equally, a genuine liability can quietly become irrecoverable for the Department if the window is missed.
Businesses would do well to maintain a simple limitation tracker across their GSTINs and financial years, log the date every notice is actually received, and flag any case where Section 73/74 is invoked for a period that should properly fall under 74A.
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