Supreme Court of India
G.R. Infra Projects Ltd. v. State of Madhya Pradesh
CIVIL APPEAL NO.11277 OF 2026
The ruling in brief
Where State issued SCN dated 13.06.2025 for 2018-19 after annual return due date was extended to 31.12.2020 and limitation period, after excluding COVID period of 1 year 2 months, expired on 28.02.2025, SCN was time-barred under general provision and interference with such notice on ground of limitation was justified
Where assessee received a show cause notice invoking extended period on grounds of fraud or concealment without specifying material facts or particulars, and State sought to rely on a counter affidavit to justify allegations, such notice was invalid as its validity must stem from inherent content, rendering extended period invocation and consequent proceedings unsustainable
Provisions considered
Section 73, read with Section 44 of Central Goods and Services Tax Act, 2017/Madhya Pradesh Goods and Services Tax Act, 2017 - Rule 80 of Central Goods and Services Tax Rules, 2017/Madhya Pradesh Goods and Services Tax Rules, 2017; Section 74 of Central Goods and Services Tax Act, 2017/Madhya Pradesh Goods and Services Tax Act, 2017