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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/combining of multiple tax periods/financial years in a single/composite show-cause notice under Section 73/74 of the CGST/KGST Act is permissible and whether the impugned show-cause notice dated 29.05.2024 that combines multiple periods is liable to be quashed.Analysis: The Court applied the legal framework governing issuance of show-cause notices under Sections 73 and 74 of the CGST/KGST Act and examined validity of issuing a solitary/composite notice encompassing multiple tax periods/financial years. The Court relied on its prior detailed ruling in M/s Pramur Homes And Shelters (WP No.33081/2025 dated 11.12.2025) which addressed identical points and concluded that combining multiple tax periods/financial years in a single show-cause notice is not authorised by the CGST/KGST scheme. On that basis the impugned notice dated 29.05.2024, which encompasses multiple tax periods, was held to be legally impermissible and to vitiate subsequent proceedings, while preserving the respondents' liberty to initiate proceedings lawfully for individual periods.Conclusion: The clubbing/consolidation/bunching/combining of multiple tax periods/financial years in a single/composite show-cause notice under Section 73/74 of the CGST/KGST Act is invalid and illegal; the impugned show-cause notice dated 29.05.2024 is quashed — decision in favour of the assessee.
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