The Hon’ble Kerala High Court in Pappachan Chakkiath v. Assistant Commissioner & Anr. [WP(C) NO. 816 of 2023 dated January 11, 2023] has held that when the time limit for issuance of an order under Section 73(10) of the Central Goods and Services Tax Act, 2017 (“the CGST Act”) for the Financial Year (“F.Y.”) 2017-18 is extended upto September 30, 2023, the only interpretation that can be placed on the provisions of Section 73(2) of the CGST Act is that, the SCN can also be issued with reference to the date September 30, 2023. Further held that there is no ambiguity in the provisions which require to apply of any rules of interpretation in favour of the assessee.