Multiple tax periods cannot be clubbed in one GST show cause notice; year-wise limitation and liability apply separately.

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....A show cause notice under the CGST Act cannot club multiple financial years into one proceeding, because liability, annual return compliance and limitation operate separately for each tax period. A single notice combining distinct years would impermissibly aggregate different due dates and limitation consequences; the impugned notice was therefore quashed. The Court also held that, within the State, its own later decisions on this point were binding, and the contrary Delhi High Court view could not prevail. The Supreme Court's in limine dismissal of the challenge to that view did not attract merger and did not displace the binding effect of the Court's decisions. Liberty was reserved to issue a fresh notice in accordance with law.....