Clubbing of tax periods in a single GST show cause notice is impermissible, rendering consolidated notices and orders invalid.

The petition contests whether a single composite show cause notice may aggregate multiple tax periods under the CGST/KGST framework; applying a prior binding determination that such consolidation is beyond the statutory authority, the consolidated notices and consequent orders covering multiple financial years are held vitiated. The legal principle applied is that show cause proceedings must be period-specific and cannot lawfully bunch distinct tax periods into one notice; outcome: the impugned composite notice dated 20.12.2022, the order dated 29.08.2025 and consequential proceedings are quashed, with liberty to initiate fresh period-specific proceedings.

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Issues: Whether clubbing/consolidation/bunching/combining of multiple tax periods/financial years in a single/composite show cause notice issued under Section 73/74 of the CGST/KGST Act, 2017 is permissible and whether the impugned show cause notice and consequential orders issued by the respondents that encompass multiple tax periods deserve to be quashed.

Analysis: The petition raises a single substantive issue concerning the permissibility of issuing a solitary/composite show cause notice that aggregates multiple tax periods/financial years under the provisions of Section 73 and Section 74 of the Central Goods and Services Tax Act, 2017 and corresponding provisions of the Karnataka Goods and Services Tax Act, 2017. Prior binding determination in M/S Pramur Homes And Shelters Vs. The Union of India and Ors. (WP No.33081/2025 dated 11.12.2025) held that clubbing or consolidation of multiple tax periods/financial years in a single show cause notice under Section 73/74 is illegal, invalid and beyond the authority conferred by the CGST/KGST Acts. Applying that legal framework, the impugned notices and orders in the present petition, which encompass multiple tax periods, fall within the scope of that ruling and are thereby vitiated. The respondents retain the statutory liberty to initiate proceedings afresh in accordance with law if they so choose.

Conclusion: Clubbing/consolidation/bunching/combining of multiple tax periods/financial years in a solitary/single/composite show cause notice under Section 73/74 of the CGST/KGST Act, 2017 is illegal and invalid; the impugned show cause notice dated 20.12.2022 and the order dated 29.08.2025 and all consequential proceedings are quashed, with liberty reserved to the respondents to initiate proceedings in accordance with law.

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