This circular provides clarification on the scope and applicability of the extension of limitation granted by the Hon’ble Supreme Court vide its order dated 27 April 2021 in the context of GST law.

It clarifies that the Supreme Court’s order extending limitation applies only to judicial and quasi-judicial proceedings, such as filing of appeals, reviews, revisions and similar proceedings where a statutory time limit is prescribed for pursuing a legal remedy. Accordingly, the period of limitation for filing appeals before appellate authorities, tribunals and courts under GST law stands extended in terms of the Supreme Court’s directions.

However, the circular clearly distinguishes such proceedings from other actions and compliances under GST. Routine statutory compliances by taxpayers, such as filing of returns or other procedural requirements, continue to be governed by timelines prescribed under the GST law and related notifications, and are not covered by the Supreme Court’s order. Similarly, actions like scrutiny of returns, issuance of summons, investigations, search and arrest, issuance of show cause notices, grant of time for replies and passing of original adjudication orders are not covered by the extension of limitation granted by the Supreme Court.

The circular further clarifies that tax authorities may continue to hear and dispose of quasi-judicial proceedings such as refund applications, revocation of cancellation of registration and adjudication proceedings, either physically or through virtual mode. Overall, the extension granted by the Supreme Court is limited to appellate and similar remedial proceedings and does not apply universally to all GST-related actions.