Common show cause notices under GST may cover multiple tax periods, with financial year references operating only for limitation.

Sections 73 and 74 of the CGST Act are explained as permitting a common show cause notice for multiple tax periods or financial years, because the statute uses the expression "any period" for notice issuance. The reference to financial year in the limitation provision is treated as only a time-limit reference point, not a restriction that confines the notice to one financial year. The prescribed notice form is also said not to control the substantive scope of the power, and its tax-period entries are described as non-mandatory. On that basis, a composite notice can validly cover both fraud and non-fraud components, while limitation and adjudication safeguards continue to apply period-wise.

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Issues: Whether a consolidated or common show cause notice under Sections 73 and 74 of the Central Goods and Services Tax Act, 2017 can validly cover multiple financial years or multiple tax periods.

Analysis: The statutory scheme of the Central Goods and Services Tax Act, 2017 distinguishes between "tax period", "financial year", "such period", and cases where no period is specified. The provisions governing returns, self-assessment, scrutiny, audit, special audit, inspection, search and seizure, and demand and recovery show that, where the legislature intended a proceeding to be confined to a particular period, it said so expressly. Sections 73 and 74 use the expression "any period" for issuance of notice, and the reference to financial year in the limitation provisions does not restrict the scope of the notice itself. The linkage to financial year in the time limit for passing the order is only a reference point for limitation and does not make the proceeding financial year-specific. The language of sub-sections enabling statements for "such periods" beyond the notice period also supports a wider construction. The prescribed form for show cause notice does not alter the substantive scope of the power, and the entries relating to tax period are not mandatory. Concerns about pecuniary jurisdiction and the coexistence of fraud and non-fraud components do not invalidate a composite notice, since limitation and adjudication safeguards continue to apply period-wise.

Conclusion: Consolidated or common show cause notices under Sections 73 and 74 covering multiple financial years or multiple tax periods are permissible and valid.

Final Conclusion: The challenge to the impugned notices failed, the orders of the learned Single Judge were set aside, and the Revenue's position was accepted.

Ratio Decidendi: Sections 73 and 74 of the Central Goods and Services Tax Act, 2017 permit a notice to cover any period, and the reference to financial year in the limitation provision does not impose a substantive restriction that confines the notice to a single financial year.

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