Composite notice for multiple assessment years held unsustainable; fresh year-wise proceedings permitted with limitation excluded.

A composite notice or order covering multiple assessment years was held unsustainable where year-wise proceedings were required. The HC accepted the challenge in light of binding Division Bench authority, quashed the impugned order, and allowed the respondent to start afresh by issuing separate notices for the relevant assessment years. The intervening period was directed to be excluded for limitation purposes, preserving the ability to initiate fresh proceedings in accordance with law.

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Issues: Whether a composite notice/order covering multiple financial years was legally sustainable, and whether the impugned order deserved interference.

Analysis: The challenge was that a single composite notice was issued for multiple assessment years. The Court accepted that such composite issuance was not sustainable in view of the binding Division Bench decisions cited before it. The Court also granted liberty to the respondent to initiate fresh proceedings by issuing separate notices for the relevant assessment years, while directing exclusion of the intervening period for limitation purposes.

Conclusion: The impugned order was quashed. The respondent was permitted to proceed afresh by issuing separate notices for the relevant assessment years, with the specified period excluded for limitation.

Final Conclusion: The writ petition succeeded on the illegality of the composite notice, and the matter was left open for fresh action year-wise in accordance with law.

Ratio Decidendi: A composite notice covering multiple assessment years is not legally sustainable where separate year-wise proceedings are required.

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