Section 74 of CGST

[Vikas Dahiya]

Respected Sir/ Madam

I humbly seek your valuable suggestions to my query We have received a SCN u/s 74 pursuant to audit u/s 65 of the CGST Act. A single SCN is issued for two years FY 2019-20 to FY 2020-21. However, the summary of SCN in Form GST DRC-01 is issued only for one year FY 2019-20. The order is also passed for consolidated period of two years but the summary of order in DRC-07 is issued only for one year FY 2019-20. My query is - Whether legality of SCN and the Order can be challenged on this ground?

AI Summary

Consolidated show cause notices may be challenged when statutory electronic summaries omit a financial year, affecting procedural validity.
Disputes under Section 74 focus on whether a consolidated show cause notice and order for multiple financial years is valid when electronically uploaded summaries (GST DRC-01 and DRC-07) cover only one year. One challenge path asserts that omission of a year in the required summary breaches procedural obligations under the CGST Rules and may render the notice or order susceptible to challenge. A separate, substantive challenge holds that each financial year is a distinct assessment period with independent limitation and natural justice implications, making consolidated SCNs vulnerable unless limitation is preserved.