Consolidated GST notices and orders across financial years are permissible under Sections 73 and 74, with severable valid periods

A consolidated show cause notice and consolidated order covering different financial years are permissible under Sections 73 and 74 of the CGST Act because Chapter XV does not prohibit clubbing of periods, and the provisions mainly regulate jurisdiction and time limits. References to notices and statements for "such periods" support a common proceeding across multiple years. The Court distinguished assessment under Chapter XII from adjudication under Sections 73 and 74, and applied severability so that time-barred periods do not invalidate the valid periods. The challenge to jurisdiction therefore failed.

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Issues: Whether the proper officer under Sections 73 and 74 of the Central Goods and Services Tax Act, 2017 could issue a consolidated show cause notice and pass a consolidated order covering different financial years.

Analysis: The statutory scheme under Chapter XV does not expressly prohibit clubbing of multiple financial years in a single notice or order. Sections 73(1) and 74(1) confer jurisdiction to initiate proceedings when the statutory conditions are met, while Sections 73(2), 73(10), 74(2) and 74(10) control only the time limits for issuance of notice and passing of order. The references in Sections 73(3), 73(4), 74(3) and 74(4) to notices or statements for "such periods" support the view that a common proceeding can cover multiple periods. The Court also distinguished assessment under Chapter XII from adjudication under Sections 73 and 74, and applied the doctrine of severability to hold that if some periods are time-barred, the valid periods need not fail with them.

Conclusion: A consolidated show cause notice and consolidated order for different financial years are permissible under Sections 73 and 74, and the challenge to jurisdiction fails.

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