Consolidation of show cause notices under CGST Act challenged; consolidated notices quashed for bypassing year-wise limitation rules

Challenge concerns validity of consolidated show cause notices that group multiple financial years. The prevailing legal position emphasises that time limits for initiating recovery and prosecution run from the due date for furnishing the annual return for the specific financial year; consolidation across years bypasses those period-specific limitation and procedural requirements, rendering the consolidated notices procedurally infirm. Consequence: consolidated SCNs covering successive assessment years were treated as invalid and quashed, requiring separate, year-wise invocation of statutory remedy periods and compliance with the statutes procedural mandates.

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The High Court of Karnataka allowed the writ petition filed by a Club challenging a consolidated show cause notice for multiple tax periods from 2019 to 2023-24 under the Central Goods and Services Tax (CGST) Act, 2017. The Court quashed the impugned show cause notices and directed the respondent to issue separate notices for each assessment year in accordance with Section 73 of the CGST Act.

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