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Issues: Whether a single show cause notice could validly be issued for more than one financial year and whether such clubbing of periods rendered the notice without jurisdiction and liable to be quashed.
Analysis: The notice was issued covering multiple financial years. The governing principle applied was that a show cause notice under the GST regime must be issued with reference to the relevant tax period, and clubbing more than one financial year in a single notice is impermissible. On that basis, the notice was treated as having been issued without jurisdiction.
Conclusion: The impugned show cause notice was quashed as invalid for clubbing more than one financial year, and the petitioner obtained relief.