Time limit to issue Notice for tax not paid/ short paid u/s 73 of CGST Act

Sub-section (10) of section 73 of CGST Act, provides “The proper officer shall issue the order under sub-section (9) within three years from the due date for furnishing of annual return for the financial year to which the tax not paid or short paid or input tax credit wrongly availed or utilised relates to or within three years from the date of erroneous refund.”

Sub-section (2) provides as “The proper officer shall issue the notice under sub-section (1) at least three months prior to the time limit specified in sub-section (10) for issuance of order.”

In view of above provision, the proper officer shall issue notice before three months of the timeline of three years of issuance of order. The year wise timeline for issuance of notice and order is given below.