Whether law strict to issue single assessment order for multiple year demand in a single SCN?
single assessment order for multiple year demand in a single SCN
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Single assessment order permissible when period-wise reasoning and fair opportunity to respond are provided and recorded.
A consolidated SCN and single adjudication order for multiple tax periods is permissible under the service tax and GST regimes only if each period is separately identified and reasoned, the noticee is given a reasonable opportunity to respond on each period, and the final order deals with each period distinctly; omnibus or vague multi period demands that lack period wise justification or deny fair hearing contravene natural justice. (AI Summary)
A consolidated SCN and single adjudication order for multiple tax periods is permissible under the service tax and GST regimes only if each period is separately identified and reasoned, the noticee is given a reasonable opportunity to respond on each period, and the final order deals with each period distinctly; omnibus or vague multi period demands that lack period wise justification or deny fair hearing contravene natural justice. (AI Summary)
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