GST jurisdiction limits on consolidated notices: writ relief allowed against void proceedings covering multiple financial years.

Under the GST regime, assessment and demand proceedings must be confined to distinct tax periods, so a consolidated show cause notice and order covering multiple financial years were beyond jurisdiction and void ab initio. The Court held that proceedings issued in breach of this statutory framework could not be sustained, and the existence of an alternate statutory remedy did not bar writ intervention where the impugned action was a nullity. The request for instalment payment did not cure the jurisdictional defect. The consolidated notice, adjudication order and recovery notice were quashed, with liberty to proceed afresh separately for each financial year if otherwise permissible in law.

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Issues: Whether the consolidated show cause notice and the consequential order covering multiple financial years under the GST regime were without jurisdiction, and whether availability of a statutory remedy barred writ interference where the impugned action was alleged to be void.

Analysis: The Court applied the GST scheme as interpreted in prior decisions to hold that assessment and demand proceedings must relate to distinct tax periods and that there is no scope for clubbing multiple financial years into one consolidated notice or order. It further held that proceedings issued in breach of this statutory framework are beyond jurisdiction and, therefore, void ab initio. On that basis, the Court held that the existence of an alternate statutory remedy could not prevent exercise of writ jurisdiction against an order that was a nullity. The petitioner's request for installment payment did not validate jurisdictionally defective proceedings.

Conclusion: The consolidated show cause notice, the adjudication order, and the consequential recovery notice were held unsustainable and were quashed, with liberty reserved to proceed afresh, if permissible, separately for each financial year in accordance with law.

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