Year-wise GST show cause notices are required when limitation under Section 73 is computed separately for each financial year.

A consolidated show cause notice covering multiple GST periods under Section 73 of the CGST Act was held impermissible because limitation under Section 73(10) is linked to the due date for the annual return of the relevant financial year, requiring year-wise examination of liability and time limits. Notices for distinct assessment years must therefore be issued separately. On that basis, the common notice covering 2019-20 to 2023-24 was invalid and liable to be quashed.

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Issues: Whether a common show cause notice covering multiple tax periods under Section 73 of the Central Goods and Services Tax Act, 2017, was valid, and whether such notices had to be issued separately for each assessment year.

Analysis: The notice under challenge covered the tax periods 2019-20 to 2023-24 in a consolidated manner. Section 73(10) ties the limitation period to the due date for furnishing the annual return for the relevant financial year, indicating that liability and limitation are to be examined year-wise. On that basis, and following the principle that assessments relating to distinct years must be treated independently, consolidation of multiple assessment years into one notice was found impermissible.

Conclusion: The consolidated show cause notice was invalid and liable to be quashed. Separate show cause notices may be issued for each assessment year in accordance with Section 73 of the Central Goods and Services Tax Act, 2017.

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