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of <h1>Single GST show cause notice clubbing multiple tax periods u/s73/74 held invalid; notice and proceedings quashed.</h1> A dominant issue was whether a single/composite show cause notice under s.73/74 of the CGST/KGST Act, 2017 could validly club/consolidate multiple tax ... Clubbing/consolidation/bunching/ combining of multiple tax periods/financial years in a Single/Composite Show cause notice issued under Section 73 / 74 of the CGST/ KGST Act, 2017 - HELD THAT:- The issue in controversy involved in the present petition also relates to clubbing/consolidation/bunching/combining of multiple tax periods/financial years/block periods in a Single/Composite Show cause notice, which has already been held to be invalid and illegal by this Court in M/S Pramur Homes And Shelters’s case [2025 (12) TMI 1188 - KARNATAKA HIGH COURT]. The impugned show cause notice dated 29.05.2024 at Annexure-B passed by respondent No.4 and all further proceedings, orders, notices etc., pursuant thereto initiated/to be initiated by the respondents are hereby quashed - Petition allowed. Issues: Whether clubbing, consolidation, bunching or combining of multiple tax periods/financial years or block periods in a single/composite show cause notice issued under Section 73 or Section 74 of the CGST/KGST Act is permissible and, if impermissible, whether the impugned composite show cause notice and consequential proceedings should be quashed.Analysis: The challenged practice involves issuing one solitary/composite show cause notice that encompasses multiple tax periods/financial years. The legal framework for assessment and adjudication under Section 73 and Section 74 of the CGST/KGST Act contemplates proceedings directed to specific tax periods and the statutory scheme does not support aggregation of distinct assessment periods into a single composite notice. Where a composite notice spans multiple discrete tax periods, the notice’s ability to comply with the statutory requirements for a show cause notice, and to provide a coherent forum for determination of liabilities for each period, is undermined. The judgment relied on the earlier authoritative determination on identical points, applying the statutory scheme to conclude that aggregation of multiple tax periods in one show cause notice is contrary to the statutory framework and results in absence of jurisdiction for the composite notice; accordingly, any further proceedings founded on such a composite notice are vitiated, subject to the respondents’ liberty to initiate proceedings compliant with the statutory procedure for individual periods.Conclusion: Clubbing/consolidation/bunching/combining of multiple tax periods/financial years in a single/composite show cause notice under Section 73 or Section 74 of the CGST/KGST Act is illegal, invalid, impermissible and without jurisdiction; the impugned composite show cause notice and all proceedings, orders and notices pursuant thereto are quashed, with liberty reserved to the revenue to initiate appropriate proceedings in accordance with law.
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