Composite GST show-cause notices for multiple tax periods under Section 74 are impermissible and without jurisdiction.

Composite show-cause notices under Section 74 of the CGST Act covering multiple tax periods or financial years are impermissible, as the Court followed its earlier ruling on the same issue and treated the mode of issuance as invalid. Because the impugned notice bundled multiple periods on that basis, the notice and all consequential proceedings were held vitiated and without jurisdiction. The respondents were left free to initiate fresh proceedings in accordance with law.

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Issues: Whether clubbing, consolidation or bunching of multiple tax periods in a single composite show-cause notice issued under Section 74 of the Central Goods and Services Tax Act, 2017 is permissible, and whether the impugned notice and consequential proceedings were liable to be quashed.

Analysis: The Court followed its earlier decision on the same legal question and held that a solitary or composite show-cause notice covering multiple tax periods or financial years under Section 74 is impermissible in law. Since the notice in question covered multiple periods and was founded on the same invalid mode of issuance, the notice and all proceedings flowing from it were treated as vitiated. The Court also preserved the respondents' liberty to proceed afresh in accordance with law.

Conclusion: The composite notice and consequential proceedings were quashed as illegal and without jurisdiction, and the petition was allowed.

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