Composite GST show-cause notices for multiple tax periods are jurisdictionally invalid, and dependent adjudication orders cannot survive.

A composite GST show-cause notice covering multiple tax periods was treated as jurisdictionally invalid, because distinct tax periods cannot be clubbed in one notice under the CGST/KGST framework. The Court applied the coordinate bench view that such bunching is without authority of law, and any adjudication founded on that defective notice cannot stand. The consequential adjudication order was therefore set aside. The assessee's willingness to face fresh proceedings was noted, and the revenue was left free to issue separate notices for each relevant tax period.

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Issues: Whether a solitary show-cause notice clubbing multiple tax periods is legally valid under the CGST/KGST regime, and whether the consequential adjudication order could be sustained.

Analysis: The challenge was confined to the jurisdictional validity of issuing one notice covering multiple tax periods. The Court followed the earlier coordinate bench view that consolidation or bunching of distinct tax periods in a single show-cause notice under the GST enactments is impermissible and without authority of law. Since the defect went to jurisdiction, the notice and the adjudication order founded on it could not be sustained. The Court also recorded the petitioner's willingness to face fresh proceedings by separate notices for each tax period, and reserved liberty to the revenue to proceed accordingly.

Conclusion: The composite show-cause notice was held invalid, and the adjudication order based on it was set aside in favour of the assessee.

Final Conclusion: The proceeding was disposed of by nullifying the impugned notice and order on the jurisdictional ground while permitting the revenue to initiate separate proceedings for the relevant tax periods.

Ratio Decidendi: Clubbing multiple tax periods in a single GST show-cause notice is impermissible and jurisdictionally unsustainable; any adjudication based on such notice cannot stand.

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