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of <h1>Single show-cause notice consolidating multiple GST periods held unauthorized despite administrative circulars; five-year composite notice quashed</h1> Whether adjudicating authority may issue a single show-cause notice under s.74 CGST consolidating multiple financial years/tax periods. Relying on prior ... Clubbing notices issued u/s 74 of The Central Goods and Services Tax Act, 2017 - lack of jurisdiction of authority to have composite assessment for different tax periods/assessment years - HELD THAT:- As could be seen, the Division Bench of this Court at Goa in M/s. Milroc Good Earth Developers Vs. Union of India & Ors. [2025 (10) TMI 867 - BOMBAY HIGH COURT] has in categorical terms held that there is no scope for consolidating various financial years/tax period while issuing show cause notice u/s 74 of the CGST Act, 2017. The Counsel for respondent nos. 1 and 2 has invited attention to a communication dated 15/9/2025 issued by the Under Secretary to the Government of India in favour of Principal Chief Commissioners/Commissioners of CGST Zones indicating that composite show cause notice for multiple financial years are legally permissible - This communication apparently runs contrary to the provisions of the CGST Act, 2017, as discussed by the Division Bench in the aforesaid judgment and, therefore, will be of no help to the respondents. Since notice hereunder is admittedly issued consolidating five years, the same will have to be set aside - Petition allowed. Issues: Whether a show cause notice issued under Section 74 of the Central Goods and Services Tax Act, 2017 that consolidates multiple financial years / tax periods (July 2017 to March 2022) is permissible, and whether the impugned composite notice dated 4/8/2024 must be quashed.Analysis: The statutory scheme prescribes tax liability tied to specific tax periods (monthly or annual returns) and contains limitation provisions for issuance of assessment orders (see Sections 73(10) and 74(10)). The amendments and transitional provisions (including Section 74A for later years) and the requirement that assessments relate to a definite tax period indicate that show cause notices should not consolidate multiple financial years into a single notice. An administrative communication permitting composite notices is inconsistent with the statutory scheme and cannot override the statutory limits. Reliance on precedent holding there is no scope for consolidating various financial years for issuance of a show cause notice under Section 74 supports setting aside the impugned consolidated notice.Conclusion: The impugned composite show cause notice dated 4/8/2024 consolidating five years is impermissible and is quashed; the respondents remain at liberty to re-issue notice strictly in terms of Section 74 of the CGST Act, 2017 if no other legal impediment exists.Ratio Decidendi: A show cause notice under Section 74 of the CGST Act, 2017 must relate to a definite tax period and cannot lawfully consolidate multiple financial years into a single composite notice; consolidation of separate tax periods for a single Section 74 notice is impermissible under the statutory scheme and limitation provisions.
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