SUN ADVISORS
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A Possible GST Litigation Storm Coming? 🚨 Circular No. 254/11/2025-GST dated 27th October 2025 clarifies who the “Proper Officer” is for proceedings under Section 122 and Section 74A. But here’s where things get interesting ⬇️ 🔍 Section 122 doesn’t even use the term “Proper Officer”. (Section 127 does) So… if notices were issued directly under Section 122 without first invoking Sections 73 / 74 / 74A, 👉 Can those notices now be challenged as invalid? 👉 Can the said circular be also challenged as it defines "Proper Officer" under Section 122 instead of Section 127? And wait… there’s more 🤯 For Section 74A, this circular is the first time the government has clarified the “Proper Officer”. So what about all the 74A notices already issued earlier? 💭 Were those notices issued without authority? 💭 Could they now be argued as void?