Consolidated GST show cause notices may cover multiple tax periods where the statute authorises notice for any period.

Sections 73 and 74 of the CGST Act permit a consolidated common show cause notice covering multiple financial years or multiple tax periods. The statutory language authorises notice for "any period" and separately uses financial-year reference only for the limitation period to pass the order, so the notice itself is not confined by implication to one financial year. The DRC-01 format and jurisdictional circulars cannot curtail the text of the statute. A common notice is not invalid merely because it spans several periods, provided each period remains within limitation and the proper officer has jurisdiction.

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Issues: Whether a consolidated 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 Act distinguishes between "tax period", "financial year", "such period" and provisions containing no period-specific restriction. Sections dealing with returns, assessment, audit, special audit and inspection show that where the legislature intended a provision to be confined to a financial year or a particular return period, it said so expressly. Sections 73 and 74, by contrast, use the expression "any period" for issuance of notice and also contemplate statements for "such periods" other than those covered by the original notice. The reference to financial year in sub-section (10) operates only as the starting point for limitation for passing the order and does not confine the notice itself to a single financial year. The format of DRC-01 and the pecuniary-jurisdiction circulars do not cut down the statutory text. A consolidated notice does not, by itself, defeat limitation or prejudice the assessee, because each period covered must still satisfy the statutory time limit and the proper officer with jurisdiction can adjudicate the matter.

Conclusion: A consolidated/common show cause notice under Sections 73 and 74 covering multiple financial years or multiple tax periods is permissible, and the contrary view was rejected.

Ratio Decidendi: Where the statute authorises notice for "any period" and separately provides limitation with reference to the financial year for passing the order, the notice itself cannot be confined by implication to a single financial year, and a court cannot read such a restriction into the provision.

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