2025 (12) TMI 1886

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....ing the show cause notice dated 04.08.2024 bearing SCN No.116/2024-25 issued by the Respondent No.2, herein marked as Annexure-A. ii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the Order-in-original dated 05.02.2025 bearing Order No. 143/2024-25/GST/JC and DIN 202502570000003303BB passed by the Respondent No.1, herein marked as Annexure-B1. iii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the online Order under section 74 and Summary of the Order in Form GST DRC-07 for the financial years July 2017 to September 2022 dated 05.02.2025 bearing Reference No. ZD2902250198258 issued by the Respondent No.1, herein marked as Annexure-B2. ....

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....oint 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 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 ....

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....wed. (ii) The impugned show-cause notice at Annexure-A dated 30.09.2025 issued by respondent No.4 and all further proceedings, orders, notices etc., pursuant thereto initiated/to be initiated by the respondents are hereby quashed. (iii) liberty to The respondents are however reserved 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....