Answer

1. F

   Facts

   DRC-01A has no separate time limit, but the show cause notice and order that may follow must be within the limits of Sec 73, 74 or 74A for that year.

2. P

   Provisions and law

   • Sec 73(10), CGST Act 2017The order under Sec 73 must be issued within three years from the due date of the annual return for the year; the notice at least three months before that.
   • Sec 74(1), CGST Act 2017Show cause notice where tax is short paid or ITC wrongly availed by fraud, wilful misstatement or suppression, for periods up to FY 2023-24.
   • Sec 74A, CGST Act 2017For FY 2024-25 onwards, one procedure for demands: notice within 42 months of the annual return due date, order within 12 months of the notice; penalty depends on whether fraud is alleged.
3. A

   Analysis

   For a Sec 73 matter, the notice must be issued at least three months before the three-year order deadline, counted from the annual return due date. If that date has passed, a later Sec 73 notice would be barred. Mention this in your reply. Under Sec 74 or 74A, longer limits apply, so check the section first.

4. C

   Conclusion

   1. 1Find the annual return due date for the year.
   2. 2Compute the notice deadline under the section used.
   3. 3Check any extensions notified for that year.
   4. 4Raise limitation in Part B if applicable.

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