Composite GST show-cause notice clubbing multiple financial years u/s73/s.74 held invalid; FY 2019-20 to 2023-24 notice quashed.

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....Clubbing multiple tax periods/financial years in a single composite show-cause notice under s.73/s.74 of the CGST/KGST Act was held impermissible because the statutory scheme treats each financial year as an independent assessment unit with separate returns, reconciliation, evaluation of transactions/ITC, and year-specific limitation; the Act does not contemplate consolidated proceedings, rendering such notices without jurisdiction. Consequently, the composite show-cause notice covering FY 2019-20 to 2023-24 and all consequential proceedings were quashed, with liberty reserved to initiate fresh action in accordance with law. - HC....