Year-wise GST liability under Section 73 requires separate notices for each financial year; consolidated notice quashed.

Section 73 of the CGST Act requires tax liability to be determined year-wise, and the limitation period under Section 73(10) runs with reference to the relevant financial year. A consolidated show-cause notice covering multiple tax periods was therefore inconsistent with the statutory scheme because each assessment year must be treated as distinct. The Karnataka High Court quashed the common notice and left the authority free to issue separate notices for each assessment year in accordance with Section 73.

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Issues: Whether a consolidated show-cause notice issued under Section 73 of the Central Goods and Services Tax Act, 2017, covering multiple tax periods, was valid.

Analysis: The challenge concerned a single notice covering the tax periods 2017-18 to 2020-21. The Court held that the scheme of Section 73 requires year-wise determination of liability, and that the time limit under Section 73(10) operates with reference to the relevant financial year. On that basis, a common notice clubbing multiple assessment years was treated as contrary to the statutory framework and the governing legal principle that each assessment year is distinct.

Conclusion: The consolidated show-cause notice was invalid and was quashed. The respondent was left free to issue separate notices for each assessment year in accordance with Section 73 of the Central Goods and Services Tax Act, 2017.

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