2026 (2) TMI 100

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....50(1) and 20 of the IGST Act, 2017 and has also sought for setting aside of Form GST-DRC-07 at Annexure-'L1' dated 16.01.2025 for the Financial Years 2017-2018 to 2021-2022 and the show cause notice dated 18.06.2024. Further, the petitioner has sought for setting aside of Form GST-DRC-01 dated 05.08.2024 at Annexure-'G' for the tax periods 2017-2018, 2018-2019, 2019-2020, 2020-2021 passed by respondent No.3 Authority. 2. The petitioner has drawn attention to the show cause notice and further submits that the period in question is from 2018-2019, 2019-2020, 2020-2021, 2021-2022. It is further submitted that single show cause notice for multiple tax periods is impermissible. 3. Reliance is placed on the order of this Court dated 17.12.2....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....answered in favour of the petitioner/tax 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 ye....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... The impugned show-cause notice at Annexure-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....