Navigating India’s Goods and Services Tax (GST) regime requires more than just timely return filing. It demands a solid understanding of the law, especially when it comes to departmental scrutiny. As GST evolves, one area that continues to catch taxpayers off guard is the issuance of GST notices, often triggered by discrepancies, audits, or compliance gaps.
Whether you’re a startup founder, an SME owner, or a tax professional, knowing when the tax department can issue a notice and under which circumstances is critical to safeguarding your business. Missing a statutory deadline, failing to respond, or not recognizing an invalid notice can lead to avoidable penalties, blocked input credits, or even legal consequences.
This comprehensive guide breaks down everything you need to know about GST notice timelines, including:
– What constitutes a GST notice?
– Who can issue it and on what grounds?
– Different types of GST notices under the CGST Act
– Time limits and deadlines you should never ignore
– Key updates introduced in 2025
– How to respond effectively and avoid escalation
– When to seek expert guidance for hassle-free resolution
Understanding your rights and responsibilities under GST can mean the difference between smooth compliance and costly disputes. Let’s dive in.
What Is a GST Notice?
A GST notice is an official communication issued by the GST department to a taxpayer for one or more reasons, such as:
– Non-filing or delayed filing of returns
– Mismatch in GSTR-1 and GSTR-3B
– Excess input tax credit (ITC) claims
– Suspected tax evasion
– Audit findings
– Non-payment or short payment of GST
Receiving a notice doesn’t always mean you’re at fault. Sometimes, it’s a routine inquiry or clarification. However, it’s important to respond correctly and on time to avoid penalties or escalations.
Types of GST Notices and Their Time Limits
Each GST notice is issued under a specific section of the Central Goods and Services Tax (CGST) Act, 2017, and each has its own statutory time limit for issuance. Here’s a breakdown:
1. Section 73: Demand Notice for Non-Fraud Cases
This section covers short payment, non-payment, or erroneous refunds without any fraudulent intent.
– Time limit to issue notice: 3 years from the due date of filing annual return for the relevant year.
– Time limit to pass the order: 3 years from the due date of annual return.
Example: For FY 2021–22, the time limit to issue notice is 31st December 2025 (assuming annual return due date is 31st December 2022).
2. Section 74: Demand Notice for Fraud Cases
This section covers cases where there is fraud, suppression, or misrepresentation of facts.
– Time limit to issue notice: 5 years from the due date of filing annual return.
– Time limit to pass the order: 5 years from the due date of annual return.
Time Barring Calendar for notices u/s 73 and 74
| Financial Year | Annual Return Due Date | Section 73 | Section 74 |
| FY 2017–18 | 05 Feb 2020 | 30 Sep 2023* | 05 Aug 2024* |
| FY 2018–19 | 31 Dec 2020 | 31 Jan 2024* | 30 Jun 2025* |
| FY 2019–20 | 31 Mar 2021 | 31 May 2024* | 30 Sep 2025* |
| FY 2020–21 | 28 Feb 2022 | 30 Nov 2024 | 31 Aug 2026 |
| FY 2021–22 | 31 Dec 2022 | 30 Sep 2025 | 30 Jun 2027 |
| FY 2022–23 | 31 Dec 2023 | 30 Sep 2026 | 30 Jun 2028 |
| FY 2023–24 | 31 Dec 2024 | 30 Sep 2027 | 30 Jun 2029 |
| FY 2024–25 | 31 Dec 2025 | 30 Sep 2028 | 30 Jun 2030 |
* Extended time limits through various notifications as mentioned below
| Financial Year | Relevant Notifications |
| FY 2017–18 | 13/2022 Central Tax dated 05/07/2022, 09/2023 Central Tax dated 31/03/2023 |
| FY 2018–19 | 09/2023 Central Tax dated 31/03/2023 & 56/2023 Central Tax dated 28/12/2023 |
| FY 2019–20 | 09/2023 Central Tax dated 31/03/2023 & 56/2023 Central Tax dated 28/12/2023 |
3. Section 61: Scrutiny Notice
Issued when a proper officer scrutinizes returns and finds discrepancies.
– No specific statutory limit, but overall time limits u/s 73 and 74 must be adhered to by the department
4. Section 65 & 66: Audit & Special Audit Notices
Audit under Section 65 can be initiated by the department, while Section 66 pertains to a special audit by a chartered accountant.
– Time limit: While the GST law doesn’t prescribe a strict deadline for notice issuance, audits must be completed within 3 months (extendable to 6 months) from the commencement date.
– As the audit concludes with an assessment u/s 73 or 74 as the case may be, overall time limits in the applicable section should be applicable
5. Section 67: Inspection, Search, and Seizure
When the officer believes there is tax evasion, inspection or seizure can be carried out.
– Notices arising from inspection or search usually follow the timeframes under Section 74.
6. Section 129: Detention of Goods in Transit
Notices under this section are issued when goods are transported without proper documentation.
– Immediate notice and action. There’s no long lead time here.
Recent Updates on GST Notices (As of 2025)
In Budget 2024 and subsequent circulars, the government reaffirmed the need for stricter enforcement of time limits to reduce litigation and improve taxpayer clarity. Some key updates:
– The GSTN portal is now flagging high-risk mismatches proactively, resulting in earlier scrutiny notices.
– A stronger risk-based selection model is in use for audits.
– The 2025 Finance Bill reiterated that demand notices under Section 73 and 74 must strictly adhere to the respective deadlines, or the entire proceedings may be rendered void.
Why Knowing GST Notice Time Limits Matters
Understanding the legal time window within which a GST notice can be issued offers several advantages:
– You can contest invalid or time-barred notices
– Helps in maintaining proper records for the required period (typically six years)
– Assists in better planning for audits and reconciliations
– Reduces the risk of unprepared compliance lapses
How to Respond to a GST Notice
1. Read the notice carefully to understand the section, reason, and deadline for response.
2. Consult a GST Consultant to assess whether the notice is valid and how to frame your reply.
3. Prepare documentation—invoices, reconciliations, returns, and clarifications.
4. File a timely response on the GST portal, and if necessary, appear before the officer.
5. Track the outcome—whether the notice is closed, escalated, or leads to a demand.
Professional Help for GST Notices and Representation
GST laws continue to evolve, and many businesses struggle to stay updated while managing daily operations. Incorrect or delayed responses can lead to hefty penalties, blocked ITC, or even cancellation of registration.
At PGA & Co. (PGACA), we provide expert assistance in:
– GST return filing and reconciliation
– Handling GST audits and notices
– Drafting replies under Sections 73 and 74
– Providing assistance in audits u/s 65 & 66
– Drafting and filing appeals against the order u/s 73 or 74 with commissioner appeals or GST tribunals
– Tax representation before authorities
– Comprehensive GST compliance management
Looking to establish your business? We also assist with Company Incorporation, Accounting & Bookkeeping, and Income Tax Filing for businesses and professionals.
Final Thoughts
GST compliance goes far beyond routine return filing. It’s about navigating a complex legal framework that governs assessments, audits, and enforcement actions. Knowing the statutory time limits for issuing GST notices can empower you to identify invalid notices, reduce exposure to tax risks, and strengthen your compliance posture.
In today’s environment of heightened scrutiny and evolving rules, even a minor oversight can lead to significant penalties—or worse, business disruption. Whether you’ve received a notice under Section 73, 74, or are undergoing a GST audit, timely and accurate representation is critical.
At PGA & Co. (PGACA), we bring deep expertise in handling GST notices, reconciliations, departmental audits, GST Appeal handling and regulatory responses. Our team works with startups, SMEs, and corporates to not just manage compliance but build long-term tax efficiency.
Don’t wait for a show-cause notice to take control of your GST strategy. Reach out to us for a tailored consultation and let our professionals guide you through every step, from documentation to resolution.