Show cause-cum-demand notices under GST may cover multiple financial years, with challenge left to the adjudicating authority.

Section 74 of the CGST Act does not, on a prima facie view, prohibit issuance of a single show cause-cum-demand notice covering a period spanning multiple financial years, so long as it is issued within the time framework under Section 74(10). As limitation under Section 74(10) was not in issue, the Bombay HC declined to entertain the writ petition at the stage of challenge to the notice and left the petitioner to raise all available objections before the adjudicating authority. The impugned notice was not interfered with.

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Issues: Whether a show cause-cum-demand notice under Section 74 of the Central Goods and Services Tax Act, 2017 could be issued for a period covering multiple financial years in one notice, and whether the writ petition challenging such notice should be entertained.

Analysis: The petition challenged the notice on the ground that separate notices ought to have been issued for each financial year. The Court noted, prima facie, that nothing in Section 74, including sub-section (1), prohibited issuance of a notice for any period, provided the notice was issued within the time framework under sub-section (10). The Court also noted that limitation under Section 74(10) was not in issue. In these circumstances, the Court was not persuaded to entertain the writ petition at the stage of challenge to the show cause notice, leaving the petitioner to raise all available contentions before the authority.

Outcome: The writ petition was disposed of without interference with the impugned show cause-cum-demand notice.

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