Year-wise GST notice requirement under Section 73 bars clubbing multiple financial years in one composite proceeding.

Section 73 proceedings under the Karnataka GST Act must be tied to the relevant financial year, with limitation counted from the due date for the annual return of that year. A composite show-cause notice and order clubbing multiple financial years from 2019-20 to 2023-24 was therefore inconsistent with the statutory scheme, and year-wise notices were required instead. The Karnataka HC accordingly set aside the impugned proceedings insofar as they covered multiple years, while preserving liberty for the authorities to start fresh separate action for each financial year in accordance with law.

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Issues: Whether a common show-cause notice and order under Section 73 of the Karnataka Goods and Services Tax Act, 2017 could validly club multiple financial years and whether the impugned action was liable to be quashed.

Analysis: Section 73 prescribes action relatable to the relevant financial year, with limitation running from the due date for furnishing the annual return for that year. A composite notice and order covering several financial years from 2019-20 to 2023-24 was therefore contrary to the statutory scheme. The proper course was to issue separate notices for each financial year and proceed year-wise in accordance with law.

Conclusion: The impugned common notice and order were invalid insofar as they clubbed multiple financial years, and the relief was in favour of the assessee.

Final Conclusion: The proceedings were set aside, while liberty was preserved for the authorities to initiate fresh year-wise action under the statute.

Ratio Decidendi: Where Section 73 action is time-linked to a specific financial year, a composite proceeding clubbing multiple financial years is impermissible and separate year-wise notices are required.

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