Year wise limitation prevents consolidation of multiple tax periods into one show cause notice; notices must respect period by period timelines.

Question determined whether a Section 74 show cause notice may consolidate multiple financial years/tax periods; the court applied the statutory scheme treating tax period and limitation year by year, tied to filing of returns and periodic assessment, and held that separate limitation and recovery timelines preclude clubbing distinct tax periods into a single notice. Allegations of fraudulent availment of input tax credit do not create an exception to the year wise limitation framework; outcome favours the assessee permitting only period specific notices and demands.

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Issues: (i) Whether a show cause notice under Section 74 of the Central Goods and Services Tax Act, 2017 can consolidate or club multiple financial years/tax periods into a single notice, including in cases alleging fraudulent availment of input tax credit.

Analysis: Section 74(1) and the limitation provisions in Sections 74(10) and 73(10) operate with reference to specific tax periods tied to the filing of returns for each financial year; tax period is defined under Section 2(106) and the statutory scheme contemplates year-wise assessment and recovery linked to annual returns. The separate time limits for demand and recovery run year by year, and provisions governing returns and assessment (including Sections 39, 44, 37 and provisions addressing payment and interest such as Section 50) reflect an annual/periodic structure. Consolidating different financial years in a single show cause notice would aggregate distinct tax periods with different due dates and limitation timelines, affecting the statutory time bar and the assessee's ability to respond period by period. The allegation of fraudulent availment of input tax credit does not, by itself, create a statutory exception permitting clubbing of separate tax periods into one consolidated notice where Section 74's year-wise limitation scheme applies.

Conclusion: Issue (i): Clubbing multiple financial years/tax periods into a single show cause notice under Section 74 of the Central Goods and Services Tax Act, 2017 is not permissible; even where fraudulent availment of input tax credit is alleged, notices must comply with the year-wise period and limitation framework. The result is in favour of the assessee.

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