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Issues: (i) Whether the petitioner could be permitted to file one consolidated appeal against the common adjudication order arising from a common show cause notice for multiple financial years. (ii) Whether the appeal, if filed within the time granted by the Court, should be protected from dismissal on the ground of limitation, and whether the petitioner could raise the grievance regarding the GST DRC-07 before the appellate authority.
Issue (i): Whether the petitioner could be permitted to file one consolidated appeal against the common adjudication order arising from a common show cause notice for multiple financial years.
Analysis: The show cause notice was common, the adjudication culminated in a common order, and the reference in the impugned order to only one financial year did not alter the fact that the dispute covered the entire period noticed in the proceedings. Requiring separate appeals merely because the form reflected one year would be unnecessarily duplicative.
Conclusion: The petitioner was permitted to file one consolidated appeal before the Appellate Authority under Section 107 of the Central Goods and Services Tax Act, 2017.
Issue (ii): Whether the appeal, if filed within the time granted by the Court, should be protected from dismissal on the ground of limitation, and whether the petitioner could raise the grievance regarding the GST DRC-07 before the appellate authority.
Analysis: In view of the demand amount and the pre-deposit requirement, time was granted for filing the appeal. The Court also directed that, if the appeal was filed within the stipulated period, it should be considered on merits and not rejected as time-barred. The objection regarding the issuance of Form GST DRC-07 was left open for consideration by the appellate authority.
Conclusion: The appeal was allowed to be filed up to 10 July 2025 with the requisite pre-deposit, and it was directed not to be dismissed on limitation if filed within that period.
Final Conclusion: The petition succeeded only to the extent of procedural relief, enabling a consolidated statutory appeal with protection against limitation, while leaving the substantive tax dispute to be decided by the appellate authority.
Ratio Decidendi: Where a common show cause notice and common adjudication order cover multiple periods, a consolidated appeal may be permitted, and procedural limitation may be relaxed to ensure adjudication on merits.
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