The Andhra Pradesh High Court has stayed further proceedings arising from a Goods and Services Tax (GST) assessment order, after allegations surfaced that the order was digitally signed beyond the legally permitted time frame.
The bench of Justice R. Raghunandan Rao and Justice Sumathi Jagadam has observed that a consolidated order for FY 2017–18 to 2022–23 was passed on 4.2.2025. However, it was digitally signed only on 12.2.2025, the DIN also bears the date 12.2.2025, and the DRC-07 was issued on 14.2.2025. For the State of Andhra Pradesh, the limitation period for FY 2017–18 expired on 7.2.2025, in view of Notification No. 06/2020-CT dated 3.2.2020 read with Section 74 of the CGST Act.
Advocate Nikhil Gupta, Counsel for the petitioner argued that while the order bore the date February 4, 2025, it was actually digitally signed on February 12, 2025 — a date falling outside the statutory five-year limitation period prescribed under Section 74 of the GST Act, 2017. He relied on Notification No.6 of 2020 dated February 3, 2020, which had fixed February 7, 2020, as the last date for filing annual returns for that assessment year. Thus, the limitation period, according to him, would expire on February 7, 2025.
To substantiate the claim, the petitioner highlighted the Document Identification Number (DIN) — DIN3712022541522 — affixed to the order. He explained that the first two digits ‘37’ represent Andhra Pradesh, while the subsequent six digits ‘120225’ signify the date February 12, 2025, indicating that the order was finalized after the expiry of the limitation period.
Given the seriousness of the issue, the petitioner sought to have the entire order quashed or, alternatively, remanded for reconsideration on the grounds of procedural illegality.
The Government Pleader for Commercial Tax, appearing for the Union of India and other respondents, requested additional time to file a counter-affidavit in response to the petitioner’s claims.
Taking note of the submissions and the prima facie case presented by the petitioner, the High Court granted a stay on all further proceedings arising from the impugned assessment order dated February 4, 2025. The matter has been posted for further hearing after the counter-affidavit is submitted.
Case Details
Case Title: Sms Limited Versus UOI
Case No.: Writ Petition No: 13275/2025
Date: 22/07/2025
Counsel For Petitioner: Srinivasa Rao Kudupudi, Nikhil Gupta
Counsel For Respondent: GP
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