Consolidation of assessment periods upheld; writ relief refused where statutory appeal remedy is available in tax proceedings.

Whether multiple financial years may be consolidated into a single notice under Sections 73 and 74 was answered by applying the precedent accepting consolidation where the statutory language permits issuance "for any period" or "for such periods"; outcome: consolidation is permissible. Whether writ relief should supplant the statutory appellate route was decided by applying the availability of an efficacious alternative remedy by appeal under the statutory regime and the principle that writ jurisdiction should not ordinarily bypass that remedy; outcome: writ relief declined and petitioner granted liberty to pursue prescribed statutory remedies. Allegations of fraudulent input tax credit were left for the appellate process.

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Issues: Whether the adjudicating authority could consolidate multiple financial years into a single show cause notice and adjudicate them together and whether the writ court should quash the Order-in-Original dated 31.01.2025 impugning such consolidation.

Analysis: The Court considered the scope of Sections 73 and 74 of the Central Goods and Services Tax Act, 2017 and the binding effect of the earlier decision in Ambika Traders which accepts issuance and consolidation of notices for multiple periods under the language "for any period" and "for such periods" in those provisions. The Court noted that it would not enter into the merits of alleged fraud or determine whether fraudulent availment of input tax credit exists, emphasising that such merits fall within the statutory appellate framework. The availability of an efficacious alternative remedy by way of appeal under Section 107 of the Central Goods and Services Tax Act, 2017 read with Rule 109A of the Central Goods and Services Tax Rules, 2017, and the principle that writ jurisdiction should not ordinarily be invoked to bypass that statutory remedy, was applied. The Court also observed that decisions of coordinate Benches departing from Ambika Traders did not relieve it from following the earlier binding decision, and that the pendency of matters before the Supreme Court did not displace the binding precedent.

Conclusion: The Court declined to interfere with the Order-in-Original dated 31.01.2025; consolidation of multiple financial years for the purposes of issuing notices and statements under Sections 73 and 74 of the Central Goods and Services Tax Act, 2017 is permissible as contemplated by Ambika Traders; the writ petition is dismissed and the petitioner is granted liberty to pursue the prescribed statutory remedies.

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