https://www.taxtmi.com/caselaws?id=792085 Under the CGST Act, limitation and tax determination operate year-wise, so a show cause notice under Section 74 ordinarily cannot club multiple financial years into one proceeding. The Court distinguished cases involving a genuinely composite, interlinked fraudulent design and held that consolidation is not sustainable unless the allegations themselves disclose such a continuing mechanism. Because the impugned notices did not do so, they were invalid, and the consequential adjudication orders also could not stand. The Court set aside the notices and resultant orders, while leaving liberty to issue fresh notices separately for the relevant financial years in accordance with law. en-us Fri, 27 Feb 2026 00:00:00 +0530 Fri, 22 May 2026 07:06:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792085 Under the CGST Act, limitation and tax determination operate year-wise, so a show cause notice under Section 74 ordinarily cannot club multiple financial years into one proceeding. The Court distinguished cases involving a genuinely composite, interlinked fraudulent design and held that consolidation is not sustainable unless the allegations themselves disclose such a continuing mechanism. Because the impugned notices did not do so, they were invalid, and the consequential adjudication orders also could not stand. The Court set aside the notices and resultant orders, while leaving liberty to issue fresh notices separately for the relevant financial years in accordance with law. Case-Laws GST Fri, 27 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792085