Case LawsGST
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Composite GST show cause notices aggregating multiple financial years lack scope; demands must be period-specific and limitation-linked.
The GST demand-and-recovery framework is period-based: tax liability and limitation are tied to returns for each tax period or financial year, and limitation is computed from the annual return due date or an erroneous return for that year. Consolidating multiple financial years into one consolidated show cause notice is outside the statutory design and constitutes a jurisdictional defect; administrative advisories cannot override the period-specific statutory scheme. Authorities may, if no other impediment exists, initiate proceedings framed strictly period-wise under the applicable demand provisions.