TaxTMI 
TaxTMI 
One SCN for the period 2008-09 to 2011-12 was issued in 19.07.2013 for the amount of Rs. 79 Lacs. After passing of two years the department realized that the SCN issued on 19.07.2013 has not covered the gross value and after considering the gross value shown in P/L account again a SCN was issued for the period 2008-09 to 2013-14 covering the period 2008-09 to 2011-12 for which SCN was already issued on 19.07.2013. This time the SCN was issued for the demand of Rs. 80512024/-. Now the question is whether the department is eligible to issue two SCN on the same issue for the same period to the same noticee. Is is not barred by limitation.
Two SCN for similar issue to a common taxpayer
12 Dec 2024 
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Limitation defence: an earlier timely SCN preserves liability for the same period even after a later consolidated SCN is issued.
An initial SCN issued within limitation for a specified period preserves the department's demand for that period even if a later consolidated SCN re includes it; overlapping SCNs can be adjudicated together but procedural lapses do not automatically bar the demand. Limitation for subsequently included years must be determined by the later SCN's date, and the department may defeat limitation by proving suppression or misdeclaration. (AI Summary)
An initial SCN issued within limitation for a specified period preserves the department's demand for that period even if a later consolidated SCN re includes it; overlapping SCNs can be adjudicated together but procedural lapses do not automatically bar the demand. Limitation for subsequently included years must be determined by the later SCN's date, and the department may defeat limitation by proving suppression or misdeclaration. (AI Summary)