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Sections 73 and 74 of the GST law do not bar a consolidated show cause notice or consolidated adjudication covering multiple financial years. Limitation must be tested separately for each financial year, but that does not deprive the proper officer of jurisdiction to issue one common notice or pass one common order. The scheme also permits statements for other periods on the same grounds, supporting multi-period proceedings. If one included year is time-barred, the entire proceeding is not void; the barred portion can be severed because each financial year is a distinct cause of action.
Sections 73 and 74 of the GST law do not bar a consolidated show cause notice or consolidated adjudication covering multiple financial years. Limitation must be tested separately for each financial year, but that does not deprive the proper officer of jurisdiction to issue one common notice or pass one common order. The scheme also permits statements for other periods on the same grounds, supporting multi-period proceedings. If one included year is time-barred, the entire proceeding is not void; the barred portion can be severed because each financial year is a distinct cause of action.
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