2026 (5) TMI 909

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.... SUNIL DUTT YADAV For the Petitioner : Sri. M.N. Shankare Gowda, Advocate For the Respondents : Sri. K. Hema Kumar, AGA ORAL ORDER: The petitioner has challenged the show-cause notice at Annexure-F as well as the order of adjudication at Annexure-N. The petitioner at the outset has raised the contention that the order of adjudication at Annexure-N relates to multiple tax periods spanni....

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....ion while directing that proceedings should emanate from separate show-cause notice for different tax periods and if such direction could be passed, petitioner would not object as regards limitation insofar as issuance of fresh show-cause notice for the relevant tax period that is to be issued separately. 3. Learned Additional Government Advocate submits that in light of the stand of the petiti....

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.... "Point No.(i) is accordingly 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 o....