Consolidated GST notices across multiple years are permissible under Section 74 where the alleged ITC fraud pattern requires year-wise assessment.

Section 74 of the CGST Act was read as permitting a consolidated show cause notice and consequential order covering multiple financial years, because the statute contains no express bar on such consolidation. The Court treated year-wise consolidation as permissible, and potentially necessary, where alleged fraudulent availment or utilisation of input tax credit requires the full transaction pattern to be examined. It declined to depart from its earlier view despite contrary opinions of other High Courts. The challenge to the consolidated notice and order therefore failed, and the writ petitions were rejected.

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Issues: Whether Section 74 of the Central Goods and Services Tax Act, 2017 permits issuance of a consolidated show cause notice and consequential order covering multiple financial years.

Analysis: The Court followed its earlier decisions holding that there is no statutory prohibition against consolidating notices for multiple financial years under Section 74 of the Central Goods and Services Tax Act, 2017. It noted that, in the context of alleged fraudulent availment or utilization of input tax credit, a consolidated notice may be permissible and may even be required to bring out the full transaction pattern. The Court also declined to depart from its consistent view merely because other High Courts had taken a different view.

Conclusion: Consolidation of show cause notices and orders for multiple financial years was held to be permissible, and the challenge to the impugned notice and order failed.

Final Conclusion: The writ petitions were rejected as the impugned consolidation under Section 74 was upheld as legally permissible.

Ratio Decidendi: In the absence of a statutory prohibition, Section 74 of the Central Goods and Services Tax Act, 2017 does not bar a consolidated show cause notice or order covering multiple financial years, particularly where the alleged evasion pattern requires year-wise consolidation for determination.

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