Invalid clubbed GST show cause notice quashed for covering multiple tax periods under the CGST and KGST Acts.

Clubbing, consolidation, bunching or combining multiple tax periods or financial years in a single show cause notice under the CGST Act, 2017 and the KGST Act, 2017 is impermissible. A notice issued for more than one period was treated as lacking authority of law, and the consequential order based on it was also vitiated. The impugned show cause notice and order were therefore quashed, while the respondents were left free to initiate fresh proceedings in accordance with law.

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Issues: Whether a solitary or composite show cause notice covering multiple tax periods is valid in law, and whether the impugned show cause notice and consequential order issued under the GST enactments warranted interference.

Analysis: The petition was decided on the basis that clubbing, consolidation, bunching, or combining multiple tax periods or financial years in a single show cause notice under the Central Goods and Services Tax Act, 2017 and the Karnataka Goods and Services Tax Act, 2017 is impermissible. Since the impugned notice and the consequential order covered multiple periods, they were treated as vitiated and lacking authority of law. The respondents were left at liberty to initiate proceedings in accordance with law.

Conclusion: The impugned show cause notice and the consequential order were quashed and the petition was allowed in favour of the assessee.

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