More often than not is the practice on section 74 of the CGST Act. Part 2.

This part is exclusively on issuance of show cause notices under section 74 where single show cause notice is issued fort multiple financial years. The division bench of the Bombay High Court has put things to rest on this issue during March 2026 by going in depth on this issue and arrived at the conclusion categorically. Reference was made to few other case laws as well before concluding and the issue is as of now settled as department to desist from taking a stand that issue is under review by Supreme Court as this this the legal stand as on date till such time verdict comes from Supreme Court otherwise.

A list of 13 case laws on single show cause notice for multiple financial years is furnished below so as the benefit all concerned who receive a single SCN for multiple financial years even after publication of this article. This list may be attached in the reply itself along with the operative portions of the respective orders.

judgements.

This issue was examined in much depth by the Bombay High Court on 09/10/2025 in the matter of M/s. Milroc Good Earth Developers, Mariposa Beach Grove Versus Union of India, Additional Director, Directorate General of India (DGGI), Pune, Additional Commissioner of Central Tax, Goa Commissionerate, Joint Commissioner of Central Tax, Goa Commissionerate, State of Goa., The Assistant Commissioner, Central Goods & Services Tax, Deputy Director, Directorate General Of Goods and Service Tax Intelligence (DGGI) Zonal Unit Pune, The Commissioner, Central Goods & Services Tax Margao. - 2025 (10) TMI 867 - BOMBAY HIGH COURT vase wherein para 26 reads as '26. For the reasons recorded above, by overruling the objections raised by Ms Desai for entertaining the Petition is merely based on the show cause notice as we find that there is no provision to club various tax periods and apart from the fact that it is also beyond the period of limitation, we find that the action of Respondent No.2 in issuing consolidated show cause notices for multiple assessment years is without jurisdiction and since it is a judicial overreach, we quash and set aside the same. The Writ Petition is made absolute in the aforesaid terms'

In a like manner in M/s. Hakikatrai and Sons, Akola Versus Union of India and Ors. - 2026 (3) TMI 248 - BOMBAY HIGH COURT, the Bombay High Court relying on earlier decisions on this issue held that the show cause notice dated 26/06/2025 issued by respondent no.4 is quashed and set aside. The respondents, however, are at liberty to re-issue notice strictly in terms of the provisions of Section 74 of the CGST Act, if there is no other legal impediment.

In a nutshell, the Madras High Court ruled on 21/07/2025 in the matter of Smt R Ashaarajaa, J. Rajendran, R. Deepak Vigneshvar And Others Versus The Senior Intelligence Officer, The Superintendent of Central Tax CGST Central Excise And Others - 2025 (7) TMI 1402 - MADRAS HIGH COURT as below:

28. In view of the above discussion, this Court pass the following orders:

(i) The GST Act permits only for issuance of show cause notice based on the tax period. Therefore, if the annual return is filed, the entire year would be considered as a tax period and accordingly, the show cause notice shall be issued based on the said annual returns.

(ii) If show cause notice is issued before the filing of annual returns, the same can be issued based on the filing of monthly returns;

(iii) If show cause notice is issued after the filing of annual returns or after the commencement of limitation, the said notice shall be issued based on the annual returns with regard to the relevant financial year.

(iv) No show cause notice can be clubbed and issued for more than one financial year since the same is impermissible in law.

(v) In these cases, without any jurisdiction, the impugned show cause notices/orders came to be issued/passed for more than one financial year, which is impermissible in law and hence, the same is liable to be quashed. Accordingly, the impugned show cause notices/orders stand quashed based on the aspect of clubbing of show cause notices for more than one financial year.

Hence it is hoped that there are no more single show cause notice for multiple financial years from now onwards. Those who have already received one SCN for more than one tax period may take advantage of the above position covered in this article.