Audit under Section 65 of CGST

[Veeresham Veerabomma]

Hi Sirs !!!

During the month of April and May, 2024 some of the Tax payers have been received Audit Notices under Section 65 of CGST Act for the year 2019-20, 2020-21 and 2021-22. Subsequent to audit findings tax payers received the adjudication orders only for the year 2019-20 under Section 73. Such piecemeal assessments /adjudications are valid ?

AI Summary

Separation of assessment years: piecemeal show-cause notices and consolidated adjudication permitted subject to natural justice safeguards.
Issuing audit notices for multiple years while issuing show-cause notices and adjudicating year-by-year to avoid time-bar is permissible; each assessment year is separable with its own limitation period. A common adjudication order consolidating multiple SCNs may be used where the issue is identical, consistent with departmental practice and adjudication manuals, but such administrative measures do not override statutory safeguards and natural justice must be observed in either piecemeal or consolidated proceedings.