Consolidation of show cause notices for multiple tax years under the CGST Act found procedurally impermissible, notice quashed

Challenge concerns consolidation of show cause notices across multiple financial years under the CGST Act; court reasoned that statutory time limits for initiating proceedings are tied to each year and require period-specific action, making consolidation contrary to the Act and applicable precedent, and therefore invalid. The legal effect is that a single consolidated show cause notice spanning distinct assessment years is procedurally impermissible and susceptible to quashing, requiring tax authorities to issue period-specific notices within the prescribed temporal framework.

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The petitioner challenged a show cause notice and order issued by the respondent for tax periods 2017-18 to 2020-21, citing improper consolidation of multiple tax periods. The court found the consolidated notice flawed, ruling in favor of the petitioner. The court quashed the impugned notice and allowed separate notices to be issued for each assessment year in compliance with the CGST Act.

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