Consolidation of short-paid GST across tax periods in Section 74 show-cause notice held ultravires; notice quashed

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....The central issue was whether a show-cause notice under Section 74 CGST could consolidate alleged short-payments across different financial years/tax periods. Relying on binding Division Bench precedent, the court held that an assessing authority lacks jurisdiction to issue composite assessment or club periods in a single notice; accordingly, such consolidation is ultravires and invalid - the September 2023 show-cause notice was quashed and set aside. The court also affirmed that a writ is maintainable where proceedings are wholly without jurisdiction, supporting the remedy granted. - HC....