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Consolidation of multiple financial years/tax periods into a single show cause notice under Section 74 of the CGST Act was contested; the court preferred subsequent Bombay High Court decisions finding such consolidation impermissible, holding that authorities within the State are bound by those later judgments and that the Delhi High Court decision does not operate as a merger where the Supreme Court dismissed review in limine. The court permitted respondents to revive the petition if Bombay High Court decisions are set aside and expressly allowed reissuance of notice strictly in terms of Section 74 if no other legal impediment exists.
Consolidation of multiple financial years/tax periods into a single show cause notice under Section 74 of the CGST Act was contested; the court preferred subsequent Bombay High Court decisions finding such consolidation impermissible, holding that authorities within the State are bound by those later judgments and that the Delhi High Court decision does not operate as a merger where the Supreme Court dismissed review in limine. The court permitted respondents to revive the petition if Bombay High Court decisions are set aside and expressly allowed reissuance of notice strictly in terms of Section 74 if no other legal impediment exists.
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