2025 (12) TMI 1880

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....ition, petitioner seeks the following reliefs: (i) Quashing the Impugned Show Cause Notice dated 03.09.2025 bearing F. No. ADT/715/2025-SG-4-CGST-ADT SCN No. 129/2025-CIR-4-ADT-1-BENGALURU, 26/BLR/ADT1/AC and DIN No. 20250957TD0000000EBAS issued by the 1st Respondent under Section 74 of the Central Goods and Services Tax Act, 2017, Karnataka Goods and Services Tax Act, 2017 as well as relevant provisions of the Integrated Goods and Services Tax Act, 2017 for the tax periods of 2019-20 to 2023-24 (Annexure 'A'); (ii) Quashing the Impugned Show Cause Notice dated 03.09.2025 bearing F. No. ADT/715/2025-SG-4-CGSTADT SCN No. 130/2025-CIR-4-ADT-I-BENGALURU, 26//BLR/ADT1/AC and DIN No. 20250957TD0000522066 issued by the 1....

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....y deem fit in the facts and circumstances of the case, in the interests of justice and equity. 2. Though several contentions have been urged by both sides in support of their respective claims, the issue in controversy between the parties is directly and squarely covered by the judgment of this Court in the case of M/S Pramur Homes And Shelters Vs. The Union of India and Ors. in WP No.33081/2025 dated 11.12.2025. 3. In the said judgment, this Court formulated two points for consideration, which reads as under: (i) Whether clubbing/consolidation/bunching/ combining of multiple tax periods/financial years in a Single/Composite Show cause notice issued under Section 73 / 74 of the CGST/ KGST Act, 2017 is permissible and valid in....

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....at the same encompasses and pertains to multiple tax periods/financial years, viz., from 2019-20 to 2023-24, which is impermissible in law and consequently, the impugned Show cause notice and all further proceedings pursuant thereto are also vitiated and deserve to be quashed reserving liberty to the respondents to initiate any action/proceedings in accordance with law. Point No.(ii) is also accordingly answered in favour of the petitioner/tax payer/assessee by holding that the impugned Show cause notice dated 30.09.2025 issued by the 4th respondent to the petitioner for the tax periods/financial years from 2019- 20 to 2023-24 under Section 74 of the CGST/KGST Act is illegal, invalid, impermissible, arbitrary and without jurisdicti....