THE HON’BLE THE ACTING CHIEF JUSTICE SUJOY PAUL AND THE HON’BLE SMT. JUSTICE RENUKA YARA WRIT PETITION No.9924 of 2025 ORDER (Per the Hon’ble the Acting Chief Justice Sujoy Paul)

Sri Y. Siri Reddy, learned counsel for the petitioner;

Sri Swaroop Oorilla, learned Special Government Pleader for State Tax, for respondent Nos.1 to 3 and Sri B. Mukherjee, learned counsel representing Sri Gadi Praveen Kumar, learned Deputy Solicitor General of India, for respondent No.4.

2. With the consent, finally heard.

3. Learned counsel for the petitioner submits that the impugned show cause notice was issued beyond the permissible statutory limitation. The tax period is 2020-2021. The impugned show cause notice was issued on 30.11.2024 and the impugned assessment order was passed on 28.02.2025. A conjoint reading of Section 73(2) and (10) of the Central Goods and Services Tax Act, 2017 (for short, ‘the Act’), made it permissible for the respondents to issue the show cause notice upto 28.11.2024 whereas, in the present case, it was issued on 30.11.2024 and therefore, it is beyond the statutory period of limitation. Reliance is placed on the judgment of Andhra Pradesh High Court in M/s. The Cotton Corpo