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The note addresses validity of a single show cause notice aggregating multiple financial years under the CGST Act: each financial year is a distinct tax period with separate limitation periods under Sections 73(10) and 74(10), so limitation runs year by year and notices must respect that structure; allegation of fraudulent availment of input tax credit permits only application of any extended limitation provided by law but does not authorise clubbing of different years into one notice. Consequence: a consolidated multi year notice is invalid to the extent of aggregation, but respondents may reissue year wise notices complying with the statutory limitation regime.
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