2026 (1) TMI 498

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....vocate For R2 And Sri. K. Hema Kumar, Aga For R3 & R4 ORAL ORDER In this petition, petitioner seeks the following reliefs: a) Issue a writ of certiorari, or a writ or order or direction in the nature of writ of certiorari and set aside the Impugned Notice vide no. ADCOM/ENF/SZ/DCCT-07/INS06/2023-24 and Reference No. MA290524278146K dated 29.05.2024 (Annexure B) issued by the Respondent No. 4 as bad in law. b) Issue a writ of certiorari, or a writ or order or direction in the nature of writ of certiorari and hold that Impugned Notice vide no. ADCOM/ENF/SZ /DCCT-07/INS-06/2023-24 and Reference No. MA290524278146K dated 29.05.2024 (Annexure B) issued by Respondent No. 4 was without jurisdiction. c) Issue a writ....

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....ax payer/assessee by holding that clubbing/ consolidation/ bunching/ combining of multiple tax periods/financial years in a Solitary/Single/Composite Show cause notice issued under Section 73/74 of the CGST/KGST Act is illegal, invalid, impermissible and without jurisdiction or authority of law and contrary to the provisions of the CGST/KGST Act. 5. So also point No.2 was also answered by this Court in favour of the petitioner by quashing the impugned Show Cause Notice by holding as under: "Re: Point No.(ii); 9. While dealing with Point No. (i) supra, I have already come to the conclusion that clubbing / consolidation / bunching/ combining of multiple tax periods/financial years in a Solitary/Single/Composite S....

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....-A dated 30.09.2025 issued by respondent No.4 and all further proceedings, orders, notices etc., pursuant thereto initiated/to be initiated by the respondents are hereby quashed. (iii) The respondents are however reserved liberty to initiate appropriate proceedings in accordance with law and if such proceedings are initiated by the respondents, petitioner would be entitled to contest / defend the same in accordance with law." 6. The issue in controversy involved in the present petition also relates to clubbing/consolidation/bunching/combining of multiple tax periods/financial years/block periods in a Single/Composite Show cause notice, which has already been held to be invalid and illegal by this Court in M/S Pramur Homes And Sh....