Clubbing multiple tax periods in composite show-cause notices declared impermissible; notices quashed with liberty to reinitiate lawfully

Clubbing or consolidation of multiple tax periods/financial years into a single composite show-cause notice is impermissible; such notices lack jurisdiction and are invalid, and therefore the impugned composite show-cause notices and all consequential proceedings are quashed with liberty for revenue to initiate fresh proceedings in accordance with law. The reasoning rests on the principle that each tax period must be separately addressed and a solitary show-cause notice combining distinct assessment periods vitiates statutory procedure, rendering subsequent orders and notices non-establishing of liability. The quashing preserves the respondents' right to reissue notices lawfully without endorsing the combined approach.

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Issues: Whether clubbing/consolidation/bunching/combining of multiple tax periods/financial years in a single/composite show cause notice under Sections 73/74 of the CGST Act is permissible and whether the impugned show cause notices dated 31.03.2022 (Annexures F and F1) issued under Section 74 are liable to be quashed.

Analysis: The issue involves the validity of issuing a solitary/composite show cause notice encompassing multiple tax periods/financial years under Sections 73/74 of the CGST Act. The matter has been considered in light of a prior judgment in M/s Pramur Homes And Shelters (WP No.33081/2025 dated 11.12.2025) which addressed the same question and concluded that consolidation/bunching of multiple tax periods in a single show cause notice is impermissible. Applying that legal principle to the present petition, the impugned notices dated 31.03.2022 (Annexures F and F1) envelop multiple tax periods and therefore fall within the scope of the invalid practice identified in the cited decision. The respondents are, however, left with the procedural right to initiate proceedings afresh in accordance with law.

Conclusion: Clubbing/consolidation/bunching/combining of multiple tax periods/financial years in a single/composite show cause notice under Sections 73/74 of the CGST Act is illegal and impermissible, and the impugned show cause notices dated 31.03.2022 (Annexures F and F1) are quashed; liberty is reserved for the respondents to initiate proceedings in accordance with law.

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