Year-wise GST notice requirement bars clubbing multiple financial years unless a composite fraud pattern is specifically shown.

Under the CGST Act, limitation and tax determination operate year-wise, so a show cause notice under Section 74 ordinarily cannot club multiple financial years into one proceeding. The Court distinguished cases involving a genuinely composite, interlinked fraudulent design and held that consolidation is not sustainable unless the allegations themselves disclose such a continuing mechanism. Because the impugned notices did not do so, they were invalid, and the consequential adjudication orders also could not stand. The Court set aside the notices and resultant orders, while leaving liberty to issue fresh notices separately for the relevant financial years in accordance with law.

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Issues: (i) Whether a consolidated show cause notice under Section 74 of the Central Goods and Services Tax Act, 2017 covering multiple financial years is legally sustainable; (ii) Whether consequential orders passed pursuant to such notices are liable to be quashed.

Issue (i): Whether a consolidated show cause notice under Section 74 of the Central Goods and Services Tax Act, 2017 covering multiple financial years is legally sustainable

Analysis: The statutory scheme under the CGST Act ties determination of tax to the relevant financial year and the corresponding annual return, so limitation operates year-wise. The Court followed its earlier decisions holding that, absent exceptional facts showing a composite or interlinked fraudulent design spanning multiple years, a single notice cannot club distinct financial years. The Delhi High Court decision permitting consolidation in cases involving a common and indivisible fraud pattern was distinguished on facts, because the present notices did not disclose such a continuing mechanism.

Conclusion: Consolidated show cause notices covering multiple financial years were held unsustainable in law, against the Revenue and in favour of the petitioners.

Issue (ii): Whether consequential orders passed pursuant to such notices are liable to be quashed

Analysis: Once the foundational notices were found to be invalid, the orders passed pursuant to those notices could not be sustained. The Court therefore set aside the final orders made in the matters where adjudication had already culminated, while leaving liberty to issue fresh notices for the respective financial years in accordance with law.

Conclusion: The consequential orders were quashed and set aside, in favour of the petitioners.

Final Conclusion: The petitions succeeded, the impugned notices and consequential orders were invalidated, and the matters were disposed of with liberty to proceed afresh only in accordance with the year-wise statutory framework.

Ratio Decidendi: A show cause notice under Section 74 of the CGST Act cannot, in the ordinary course, consolidate multiple financial years unless the allegation itself discloses a composite and interlinked fraudulent design justifying such consolidation.

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