Year-specific Limitation: Composite GST show cause notices across multiple years are unsustainable; separate yearly notices required.

Year specific limitation governs initiation under the CGST scheme: limitation is tied to the annual return due date for each financial year, so officers lack competence to issue a single composite show cause notice and consolidated adjudication covering multiple assessment years. Consolidated notices can curtail an assessee's opportunity to adduce evidence, multiply assessed liability and appellate pre deposit burden, and thus exceed officer powers absent a statute providing a common initiation/completion period. Consequent outcome: composite multi year notices and orders are unsustainable and were quashed, with liberty to issue separate notices year wise.

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Issues: Whether officers are competent under Sections 73 and 74 of the Central Goods and Services Tax Act, 2017 to issue a single composite show cause notice and pass a consolidated adjudication order covering multiple financial/assessment years.

Analysis: The statutory scheme governing initiation and limitation under Section 74 requires the determination year-wise because the limitation for adjudication is pegged to the due date for furnishing the annual return of the specific financial year to which the tax not paid or short paid or input tax credit wrongly availed or utilised relates. Consolidated notices covering multiple years can curtail the period available to an assessee to adduce evidence and defend years whose limitation period would otherwise expire later, and can multiply the assessed liability and appellate pre-deposit burden contrary to the year-specific language of subsections (9) and (10) of Section 74. Prior decisions holding composite notices unsustainable explained that consolidated adjudication is permissible only where a statute provides a common initiation and completion period; comparable provisions in other Acts (for example Section 28 of the Customs Act, 1962 and Section 11A of the Central Excise Act, 1944) demonstrate that year-agnostic consolidation is statute-specific. Orders dismissing Special Leave Petitions in limine do not operate as precedents on the merits and therefore do not preclude application of the Division Bench reasoning that consolidated notices cause prejudice and exceed officer powers under the CGST scheme.

Conclusion: Composite show cause notices and consolidated adjudication orders for multiple financial/assessment years issued under Sections 73 and 74 of the Central Goods and Services Tax Act, 2017 are unsustainable; the impugned composite notices and orders are quashed, with liberty to issue separate notices for each relevant assessment year and complete proceedings in accordance with law.

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