Clubbed show-cause notices are impermissible where the tax period is annual; single multiyear notice quashed, separate proceedings allowed.

Issuance and clubbing of a single show cause notice/assessment order for multiple financial years is impermissible where the tax period is the annual return period; show cause notices issued after filing of annual returns or after commencement of limitation must relate to each year separately. Applying that principle, the impugned order that aggregated assessments for five financial years exceeded jurisdictional limits and was quashed, the show cause notice set aside, and the respondent granted liberty to initiate separate proceedings year-wise in favour of the assessee.

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Issues: Whether issuance and clubbing of a single show cause notice/assessment order for multiple financial years (2019-20 to 2023-24) is permissible and whether the impugned assessment order dated 29.10.2025 and consequential orders can be quashed.

Analysis: The Court examined the legality of issuing a single show cause notice/assessment order covering more than one financial year. The decision follows this Court's earlier ruling dated 21.07.2025 in W.P.Nos.29716 of 2024, etc., which held that the GST regime contemplates issuance of show cause notices tied to the tax period; where annual returns are filed the year constitutes the tax period, show cause notices issued after annual returns or after commencement of limitation must be based on annual returns, and no notice can be clubbed for more than one financial year. Applying that legal framework to the facts, the impugned order in the present case was issued covering the financial years 2019-20 to 2023-24, thereby exceeding jurisdictional limits by clubbing multiple years in a single notice/order.

Conclusion: The impugned assessment order dated 29.10.2025 and all consequential orders are quashed and the show cause notice dated 02.07.2025 is set aside; liberty is granted to the respondent to initiate separate proceedings for each financial year. The decision is in favour of the assessee.

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