Section 74 CGST procedure: consolidated tax notices, hearing grievance, and year-wise DRC-07 upload, with appellate remedy preserved.

A consolidated show cause notice and consequential orders covering multiple financial years under Section 74 of the CGST Act were challenged in writ jurisdiction, along with a complaint of no effective hearing. The court recorded the department's stand that summons were issued, statements were taken, and a personal hearing notice was emailed. It noted that Section 74 permits notice for the relevant period and directed the department to upload DRC-07 year-wise and intimate the taxpayer to avoid dispute. The taxpayer was left free to pursue the statutory appeal, and the writ petitions were disposed of without adjudicating the merits of the tax demands.

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Issues: Whether a consolidated show cause notice and order covering multiple financial years under Section 74 of the Central Goods and Services Tax Act, 2017 could be interfered with in writ jurisdiction, and whether the petitioner should be relegated to the statutory appellate remedy.

Analysis: The petitions assailed the impugned orders raising tax demands for multiple financial years and also raised a grievance regarding absence of a hearing. The order notes the respondents' stand that summons were issued, statements were recorded, and notice of personal hearing was sent by email. It further records that Section 74 of the Central Goods and Services Tax Act, 2017 permits issuance of a show cause notice for the relevant period. To avoid controversy, the department was directed to upload DRC-07 year-wise and intimate the petitioner. The petitioner was left free to challenge the impugned orders in appeal under the statutory scheme.

Outcome: The writ petitions were disposed of without final adjudication on the merits of the impugned demands, with liberty to pursue the statutory appeal and with directions for year-wise DRC-07 upload.

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