GST proceedings must be limited to the relevant tax period; clubbing multiple financial years in one order is impermissible.

GST proceedings cannot be clubbed across multiple financial years in a single show cause notice or adjudication. Applying its earlier view, the HC held that assessment and rectification proceedings must be confined to the relevant tax period, and that a composite order covering July 2017 to March 2023 was without jurisdiction. The impugned assessment order and the consequential rectification rejection order were quashed, with liberty reserved to the respondent to commence separate proceedings for each financial year.

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Issues: Whether the impugned assessment order and consequential rectification rejection order, passed on the basis of clubbing multiple financial years into a single proceeding, were legally sustainable.

Analysis: The challenge concerned issuance and adjudication of a single proceeding covering more than one financial year. The Court followed its earlier view that, in GST matters, show cause notice and consequential proceedings must be confined to the relevant tax period and cannot be clubbed across multiple financial years. Applying that principle, the Court held that the impugned order had been passed without jurisdiction for the period from July 2017 to March 2023, and such clubbing was impermissible in law.

Conclusion: The impugned assessment order dated 06.01.2025 and the consequential rectification rejection order dated 30.04.2025 were quashed. Liberty was reserved to the respondent to initiate separate proceedings for each financial year.

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