Consolidated show cause notice for multiple financial years invalidated; respondent may issue separate notices for each year.

Challenge to a consolidated show cause notice issued under GST for multiple financial years: the consolidated issuance was found improper because assessment inquiries must be period-specific; segregation of liabilities within a single notice does not cure the defect, and the impugned consolidated SCN and its summary were set aside. The respondent was permitted liberty to issue distinct show cause notices for each financial year and proceed accordingly. The decision relies on review of relevant precedent addressing the scope of assessment inquiries and the invalidity of combined notices spanning separate assessment periods.

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Issues:
1. Can the respondent issue one show cause notice for several financial yearsRs.

Detailed Analysis:
The petitioner, involved in the restaurant business and registered under the Central Goods and Services Tax Act, 2017, challenged a show cause notice alleging erroneous Input Tax Credit availed from January 2018 to August 2022. The petitioner contended that separate notices should have been issued for each financial year, citing past court decisions supporting this argument. The respondent, however, defended the consolidated notice, stating no legal prohibition against it and detailing the erroneous claims and penalties in the summary notice.

The primary issue before the court was whether the respondent could issue a single show cause notice covering multiple financial years. Citing a previous decision in a similar matter, the court highlighted that each financial year's liability constitutes a distinct cause of action due to varying tax rates, interests, and penalties. The court emphasized that notices for different years could have different time limitations, justifying the need for separate notices.

The court analyzed the impugned show cause notice, clarifying that it indeed covered the entire period from January 2018 to August 2022. Despite the summary segregating liabilities by financial year, the court relied on precedent and held that a consolidated notice was impermissible. Consequently, the court set aside the show cause notices, granting the respondent the liberty to issue separate notices for each financial year and proceed lawfully against the petitioner.

In the final order, the court explicitly set aside the original show cause notice and its summary, reserved the respondent's right to issue separate notices for individual financial years, and disposed of the writ petition, thereby concluding the legal proceedings on this matter.

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