Composite show cause notices for multiple assessment years are unsustainable; year-wise notices may be issued afresh.

A composite show cause notice covering multiple assessment years was held unsustainable, following the Kerala HC's earlier Division Bench rulings that year-wise proceedings are required. The petitioner's objection to the combined notice was accepted, and the notice was quashed. The respondents were left free to issue separate notices for each relevant assessment year and proceed afresh. The period from the date of the notice until receipt of a certified copy of the judgment was directed to be excluded for limitation purposes in any fresh proceedings.

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Issues: Whether a consolidated show cause notice covering multiple financial years was legally sustainable.

Analysis: The challenge was to the validity of a composite notice issued for several assessment years together. The Court followed its earlier Division Bench decisions holding that issuance of a combined notice for multiple assessment years is not legally sustainable, and found merit in the petitioner's objection. On that basis, interference was warranted.

Conclusion: The consolidated show cause notice was quashed, and the respondents were given liberty to issue separate notices for the relevant assessment years. The period from the date of the notice until receipt of a certified copy of the judgment was directed to be excluded while computing limitation for fresh proceedings.

Final Conclusion: The writ petition succeeded to the extent of setting aside the composite notice, while preserving the respondents' right to proceed afresh year-wise.

Ratio Decidendi: A composite show cause notice covering multiple assessment years is not sustainable where separate year-wise proceedings are required; such notice may be quashed with liberty to initiate fresh proceedings individually for each relevant year.

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