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Composite GST proceedings covering multiple tax periods were treated as without jurisdiction because the statutory scheme contemplates assessment with reference to a definite tax period, not consolidation of several financial years in one show cause notice. The composite notice, adjudication order and consequential recovery action were therefore void, and fresh notices may be issued separately for the relevant financial years if otherwise permissible in law. A void proceeding could not be validated by admission of liability, a request for instalments, estoppel, waiver or acquiescence, and the existence of an alternate statutory remedy did not bar writ interference where inherent jurisdiction was lacking.
Composite GST proceedings covering multiple tax periods were treated as without jurisdiction because the statutory scheme contemplates assessment with reference to a definite tax period, not consolidation of several financial years in one show cause notice. The composite notice, adjudication order and consequential recovery action were therefore void, and fresh notices may be issued separately for the relevant financial years if otherwise permissible in law. A void proceeding could not be validated by admission of liability, a request for instalments, estoppel, waiver or acquiescence, and the existence of an alternate statutory remedy did not bar writ interference where inherent jurisdiction was lacking.
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