2025 (12) TMI 1845

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....647 of 2022 (T - RES) - -<br>GST<br>Hon&#39;ble Mr. Justice S.R. Krishna Kumar For the Petitioner : Sri. Sandeep Huilgol., Advocate. For the Respondents : Sri. Akash B Shetty., Advocate For R1 To R5; Sri. K. Hema Kumar, Aga For R6. ORAL ORDER In this petition, petitioner seeks the following reliefs: "(i) Quashing the impugned order dated 20.06.2022 bearing OiO No. 06/GST/2022-23 and DIN 2022055700000016081D. passed by the 1st Respondent under Section 74 of the Central Goods and Services Tax Act, 2017, for the tax periods July 2017 to March 2020 together with the annexed computation sheet (Annexure A); (ii) Declaring that the denial of Input Tax Credit to the Petitioner solely on the basis of a mere mismatch bet....

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....ner by holding as under: Point No.&nbsp;(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 of the CGST/KGST Act. 5. So also point No.&nbsp;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.&nbsp;(ii); 9. While dealing with Point No. (i) supra, I have already come to the conclusion that clubbing /....

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....llowing: ORDER (i) Petition is hereby allowed. (ii) The impugned show-cause notice at Annexure-A dated 30.09.2025 issued by respondent No.&nbsp;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/Co....