Consolidation of single SCN across years upheld where alleged fraudulent ITC of Rs 41 crore; appeal allowed under Section 107

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....The HC dismissed the petition and upheld that consolidation of a single SCN for multiple years is permissible where Input Tax Credit in excess of Rs. 41 crores is alleged to have been fraudulently availed; the primary allegation against the Petitioner mirrors that precedent. The court recorded that the impugned order is appealable under Section 107 of the CGST Act, 2017, and granted the Petitioner liberty to file an appeal by 30 September 2025 upon making the requisite pre-deposits. If the appeal is instituted within the stipulated period, the Appellate Authority is directed not to reject it on limitation grounds but to decide the matter on its merits.....