2026 (1) TMI 834

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....s. For the Respondents: Mr. Anup Rattan, A.G. with Mr. Sushant Keprate, Addl. A.G. VIVEK SINGH THAKUR, JUDGE (ORAL) 1. The petitioner has approached this Court being aggrieved by the composite intimation of tax liability communicated to the petitioner for the financial years 2017-18 to 2023-24 vide communication dated 20.6.2024 (Annexure P-1) issued, in form DRC-01A, under Section 74(5) o....

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.... there is no bar in issuing composite notice for various financial years by clubbing the issue(s), where issue and subject matter involved in different financial years are one and the same and competent authority was and is having jurisdiction to issue composite notice by clubbing the same issue(s) and subject matter of different financial years under Section 74 of the CGST Act. 4. Learned coun....

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....1A has also not been considered at the time of issuance of DRC-01. 7. Learned Advocate General has not disputed the aforesaid contention but has submitted that limitation period for decision to be taken by the Competent Authority with respect to Show Cause Notice issued under DRC-01 was till 31.12.2025 and as no reply to Show Cause Notice was filed by the petitioner, the Competent Authority has....

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....ashed and set aside along with all consequential orders issued in pursuance thereto, but with liberty to the respondents to take appropriate action in accordance with law on or before 15.12026, if so required and thereafter proceed further as per relevant provisions of law. 9. Needless to say, the petitioner shall participate in the proceedings as required under the law, failing which Competent....