GST show-cause notice limitation requires timely portal service; internal generation and later upload cannot cure statutory invalidity.
Case-Laws
GST
Section 73's three-month minimum period for issuing a GST show-cause notice before the deadline for an order is mandatory and preserves a meaningful opportunity to respond. Extension of the outer time limit for the order does not extend the deadline for issuing notice unless the statute provides otherwise. A notice created only in an internal system, awaiting GSTN confirmation and lacking a CRN, is not issued or served where it is neither integrated with the common portal nor otherwise communicated to the taxpayer. Later portal upload cannot retrospectively cure limitation; scrutiny communications and hearing opportunities cannot replace a foundational notice.
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