29.10.2025: CBIC Prescribes Officer-Wise Monetary Limits for Proper Officers under Sections 74A & 122 of the CGST Act

The CBIC has issued Circular No. 254/11/2025-GST dated 27.10.2025, exercising powers under Clause (91) of Section 2 of the CGST Act read with Section 20 of the IGST Act, assigning functions and prescribing monetary limits for proper officers to issue show cause notices (SCNs) and adjudicate orders under Section 74A (newly inserted) and Section 122 of the CGST Act, 2017.

A. Proper Officers Assigned

Additional/Joint Commissioner, Deputy/Assistant Commissioner, and Superintendent of Central Tax – designated as proper officers for functions under Section 74A – determination of tax in cases other than fraud (newly notified provision), Section 122 – imposition of penalties, Rule 142(1A) – pre-show cause notice communication.

B. Monetary Limits for Adjudication

Officer Section 74A – Tax Demand Limit Section 122 – Penalty Limit
Superintendent Up to ₹10 lakh (CGST) / ₹20 lakh (IGST or combined) Up to ₹10 lakh (CGST) / ₹20 lakh (IGST or combined)
Deputy/Assistant Commissioner Above ₹10 lakh & up to ₹1 crore (CGST) / ₹2 crore (IGST or combined) Above ₹10 lakh & up to ₹1 crore (CGST) / ₹2 crore (IGST or combined)
Additional/Joint Commissioner Above ₹1 crore (CGST) / ₹2 crore (IGST or combined) Above ₹1 crore (CGST) / ₹2 crore (IGST or combined)

C. Additional Clarifications

  • Combined Tax Basis: Where a show cause notice under Sections 73, 74, or 74A involves both Central Tax and Integrated Tax (including cess), the determination of the proper officer shall be based on the combined amount of tax, regardless of individual tax components. Also, where a Show Cause Notice under Section 122 of the CGST Act, 2017 involving demand of penalty pertaining to both Central Tax and Integrated Tax, the proper officer shall be determined on the basis of the combined amount of penalty for both levies.
  • Subsequent Statements (Sections 73/74/74A(3) & (4)): When additional tax periods are covered under Section 73, 74, or 74A, proper officers are determined based on the highest tax demand. If the demand in a later statement exceeds the earlier officer’s monetary limit, a corrigendum shall be issued, and the case transferred to the higher-ranked officer competent to adjudicate. If no change in monetary limit occurs, the same officer continues to handle the case.
  • Tax Amount Only: The monetary limit is determined solely on the amount of tax demanded, excluding penalties.
  • Audit Commissionerates: For notices issued by Audit Commissionerates, any subsequent statements under Sections 73/74/74A (3) & (4) must be made answerable to the adjudicating authority mentioned in the original show cause notice.
  • Section 75(2) Cases: When an appellate authority, tribunal, or court holds that a notice under Section 74(1) is not sustainable (due to failure to prove fraud, wilful misstatement, or suppression), the same adjudicating officer shall determine tax under Section 73(1).

To read the complete Circular https://taxo.online/wp-content/uploads/2025/10/Circular-No-254-11-2025-cgst-28102025.pdf

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