Separate show cause notices required for each taxation period; common notice covering multiple periods was set aside.

A common show cause notice covering multiple taxation periods was unsustainable because each taxation period or financial year requires a separate initiation for assessment of tax and related liabilities. Following its earlier view, the HC held that different periods cannot be clubbed into one notice, and the impugned common notice was set aside.

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Issues: Whether a common show cause notice covering multiple taxation periods was sustainable.

Analysis: The impugned notice covered more than one taxation period. The Court followed its earlier view that assessment of tax and related liabilities for each taxation period or financial year must be initiated through separate show cause notices and that different taxation periods cannot be clubbed into one notice.

Conclusion: The common show cause notice was set aside as unsustainable.

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