Consolidation of Single SCN Across Years Allowed for Alleged Fraudulent ITC; Appeal Permitted Under Section 107 CGST Act

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....The HC dismissed the petition challenging consolidation of a single SCN spanning multiple tax years concerning alleged fraudulent availing of Input Tax Credit exceeding Rs.89 crores, holding that consolidation is permissible where primary allegation is fraudulent ITC. The court observed the impugned order is appealable under Section 107 of the CGST Act, 2017, and accordingly disposed of the petition while granting the Petitioner liberty to file an appeal by 30 September 2025 subject to compliance with requisite pre-deposit conditions. The disposal is without prejudice to the appellate forum's adjudication on merits and any statutory or equitable defenses available to the parties.....