IN THE HIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH Date of Decision : 17.02.2026 SAAR TRADERS …. PETITIONER V/S SUPERINTENDENT, CGST, RANGE IV, DIVISION MOHALI AND ANR …. RESPONDENTS CORAM : HON'BLE MRS. JUSTICE LISA GILL HON'BLE MR. JUSTICE RAMESH CHANDER DIMRI Present : Mr.G.S.Dhillon, Advocate for the petitioner.

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LISA GILL, J. (Oral)

1. Prayer in this writ petition is for setting aside order dated 28.01.2025 passed by respondent No.1 under Section 73(9) of the Central Goods and Services Tax Act (for short ‘the Act’) raising demand of tax alongwith interest and penalty.

2. Learned counsel for petitioner vehemently argues that impugned order is illegal and arbitrary. Show cause notice dated 18.11.2024 issued under Section 73(1) of the Act is stated have been issued beyond limitation provided in Section 73(2) of the Act. Reply thereto was filed by the petitioner on 09.01.2025. However, the authority has wrongly passed order dated 28.01.2025 statedly beyond limitation period provided under Section 73(10) of the Act.

3. It is noticed that this writ petition challenging order dated 28.01.2025 statedly received on 03.02.2025 has been filed on 06.02.2026. Upon query by this Court as to