Composite show cause notice cannot club separate registered divisions' demands; notice and order-in-original quashed.

A composite show cause notice was held unsustainable where demands relating to five separately registered divisions were clubbed together despite each division filing returns independently. The court treated the separate registrations as requiring distinct consideration and found that a single consolidated proceeding could not be used to raise demands for different divisions under the service tax and GST transitional framework. The composite notice and the consequential order-in-original were quashed.

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Issues: Whether a composite show cause notice and the consequential order-in-original could be sustained when demands relating to five separately registered divisions were clubbed together.

Analysis: The petitioner's five divisions were separately registered and filed returns independently. The notice, however, consolidated demands relating to distinct divisions in one proceeding. Such clubbing of separate demands was held impermissible, particularly where the demands were sought to be raised under Section 73(1) of the Finance Act, 1994 read with Section 174 of the Central Goods and Services Tax Act, 2017.

Conclusion: The composite show cause notice and the order-in-original were quashed.

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