Answer

1. F

   Facts

   Orders have fixed time limits: three years from the annual return due date under Sec 73(10), five years under Sec 74(10), and under Sec 74A for FY 2024-25 onwards, 12 months from the notice, extendable by six months. Covid-period extensions were notified for some early years.

2. P

   Provisions and law

   • Sec 73(10), CGST Act 2017Order within three years from the annual return due date
   • Sec 74(10), CGST Act 2017Order within five years from the annual return due date
   • Sec 74A, CGST Act 2017Single demand provision for FY 2024-25 onwards, fraud and non-fraud cases
3. A

   Analysis

   To test limitation, find the annual return due date for that year, including any notified extension, and add the period. If the order is later, limitation is a strong ground. Extensions notified for FY 2017-18 to 2019-20 need care, so check the notifications that applied to that year before arguing.

4. C

   Conclusion

   1. 1Find the GSTR-9 due date for the year and any extension
   2. 2Add three or five years as the section requires
   3. 3Compare with the order date
   4. 4Raise limitation as a ground if the order is late

General guidance from TaxSavvy’s library of money processes. Laws change; your Savvy confirms the answer on your exact case before anything is filed.