Parallel show cause proceedings for the same tax period must be clubbed before one proper officer after reply.

Parallel adjudication on separate show cause notices for the same tax period, issued from the same jurisdictional office and leading to nearly identical demands, was not sustainable. The proceedings were required to be clubbed before one proper officer, especially where the taxpayer had not been able to file replies to the notices. The impugned orders were set aside, and the matter was remitted for fresh adjudication after giving the taxpayer an opportunity to respond, with completion to follow the statutory time prescribed for adjudication.

---

---

Issues: Whether two adjudication orders arising from separate show cause notices for the same tax period and creating nearly identical demands could be sustained, and whether the proceedings were liable to be clubbed for fresh adjudication after granting an opportunity to respond.

Analysis: The notices and the resulting orders related to the same tax period and were issued by officers of the same jurisdictional office, while the demands were substantially identical. The petitioner also had not been able to file responses to the show cause notices. In these circumstances, continued separate adjudication on parallel notices for the same period was not , and the proceedings required consolidation before one proper officer. The petitioner was to be afforded an opportunity to file a reply, after which adjudication was to proceed within the statutory time contemplated for completion of proceedings.

Conclusion: The impugned orders were set aside, the show cause notice proceedings were clubbed, and the matter was directed to be re-adjudicated by one proper officer after receipt of the petitioner's reply.

---