Quashing consolidated show-cause notices that clubbed multiple years, holding demands must respect Sections 73 and 74 CGST Act.

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....The HC quashed consolidated show-cause notices issued by Respondent No.2 that clubbed multiple financial years for demand of GST and reversal of alleged ineligible ITC, holding such consolidation to be without jurisdiction and a judicial overreach. The court reaffirmed the statutory limitation scheme under the CGST Act, 2017 - tax periods are tied to returns (monthly or annual) and demands must respect the time limits in Sections 73 and 74 - so SCNs must be framed with reference to discrete financial years. Prior observations by a coordinate bench were noted but the HC granted the petition and set aside the impugned consolidated notices.....