2026 (5) TMI 1721

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....itioner has sought for setting aside of Form GST-DRC-07 for the Financial Year 2017-2018 as well as for the Financial Year 2019-2020 and has also sought for an order of restraint from the respondents from implementing the demand. 2. The petitioner has also assailed the validity of show cause notice contending that the same is one without jurisdiction, as the period in question relates to the tax periods, 2017-2018, 2018-2019 and 2019-2020. 3. It is submitted that a single notice cannot be issued with respect to the multiple years. 4. Reliance is placed on the order of this Court dated 17.12.2025 passed in W.P.No.22726/2025 in the case of M/s. Lakshmi Venkateshwara Traders MS Scrap v. The Deputy Commissioner of Central Tax and Anoth....

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....ial 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 years in a Solitary/Single/ Composite Show cause notice issued under Section 73 / 74 of the CGST / KGST Act is illegal, invalid, impermissible and wit....

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....o 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 illegal by this Court in M/S Pramur Homes And Shelters's case referred to Supra. 7. Under these circumstances, the impugned show cause notices bo....