Composite GST show cause notice for multiple tax periods is impermissible, and all consequential proceedings were quashed.

A single composite show cause notice clubbing multiple tax periods or financial years under the GST framework is impermissible and without jurisdiction. Applying the earlier coordinate-bench view, the Karnataka HC treated the consolidated notice as defective because it covered several periods in one proceeding. The adjudication order founded on that notice, along with the related GST forms and consequential proceedings, could not survive and were quashed. Liberty was reserved to proceed afresh in accordance with law.

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Issues: Whether a single show cause notice covering multiple tax periods or financial years under the GST regime is valid, and whether the consequent adjudication order and further proceedings could survive.

Analysis: The challenge was founded on the defect in issuing one consolidated notice for several tax periods spanning multiple financial years. The Court followed the earlier coordinate-bench view that clubbing, consolidation, bunching, or combining of multiple tax periods into one composite show cause notice is impermissible in law. Since the notice in the present case covered a long span of periods, it was treated as defective. Once the foundational notice was held unsustainable, the adjudication order passed on that basis and all consequential proceedings also could not stand.

Conclusion: The composite show cause notice was held invalid, and the order-in-original, the related GST forms, and the consequential proceedings were quashed, with liberty reserved to the respondents to proceed afresh in accordance with law.

Ratio Decidendi: A single composite show cause notice clubbing multiple tax periods or financial years is impermissible and without jurisdiction under the GST framework, and any adjudication or consequential action founded on such a notice is liable to be quashed.

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