Relegation to statutory appellate remedy affirmed; observation on single show cause notice spanning multiple years set aside.

Relegation to the statutory appellate remedy under the Central Goods and Services Tax framework was treated as appropriate while an observation that a single show cause notice covered multiple financial years was unnecessary and has been set aside. The analysis concluded the appellate relegation rendered the comment on the correctness and jurisdictional validity of a consolidated notice otiose, warranting limited interference to expunge that specific observation while leaving the remainder of the impugned direction intact and the writ appeal unentertained.

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Issues: Whether the observation in the impugned order that a single show-cause notice was issued in respect of three financial years (and was therefore erroneous) should be sustained, and whether interference with the writ appeal is warranted.

Analysis: The impugned order relegated the respondent to the statutory appellate remedy under Section 107 of the Central Goods and Services Tax Act, 2017. While doing so, an observation was recorded that issuance of a single show-cause notice covering three financial years was erroneous. The appellate relegation rendered the observation unnecessary because it touched upon the correctness and jurisdiction concerning issuance of the notice rather than affecting the availability of the statutory remedy. In that context, limited interference was considered appropriate to remove an unnecessary comment addressing jurisdiction and correctness of the common notice, while leaving the remainder of the impugned order intact.

Conclusion: The observation that a single show-cause notice was erroneous (in respect of three financial years) is set aside; otherwise the writ appeal is not entertained. This limited interference is in favour of the Revenue.

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