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The HC allowed the petition and quashed the composite SCN and resultant assessment order issued by the respondents insofar as they aggregate multiple financial years into a single proceeding. The court held Sections 73/74 (including sub-sections prescribing 3/5-year limitation) treat each financial year as a distinct tax period; therefore issuance of a single SCN spanning more than one financial year is impermissible and results in jurisdictional overreach rendering the order void ab initio. The HC directed that show-cause notices and assessments must be year-specific in accordance with the limitation scheme and statutory safeguards, and that annual returns delineate the applicable tax period for issuance of SCNs.
The HC allowed the petition and quashed the composite SCN and resultant assessment order issued by the respondents insofar as they aggregate multiple financial years into a single proceeding. The court held Sections 73/74 (including sub-sections prescribing 3/5-year limitation) treat each financial year as a distinct tax period; therefore issuance of a single SCN spanning more than one financial year is impermissible and results in jurisdictional overreach rendering the order void ab initio. The HC directed that show-cause notices and assessments must be year-specific in accordance with the limitation scheme and statutory safeguards, and that annual returns delineate the applicable tax period for issuance of SCNs.
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