Electronic GST Summaries Do Not Reset Limitation Dates

The Delhi High Court has held that later dates appearing on electronic GST summary forms do not, by themselves, make timely notices or adjudication orders time-barred. Justices Anil Kshetrapal and Bharat Parashar said Forms DRC-01 and DRC-07 summarise substantive documents; they do not replace the show-cause notice or adjudication order for calculating limitation under Section 74 of the CGST Act. The petitioner’s notices and orders were issued within the asserted statutory periods, although the electronic summaries were generated later. Challenges to fraud allegations, input-tax-credit liability, evidence and penalty required examination by the appellate authority rather than conversion of writ jurisdiction into an appeal. The petitions were disposed of on 5 October 2026 with liberty to pursue Section 107 appeals and seek exclusion of time spent before the High Court.