Consolidated Show Cause Notices: permissibility affirmed by one high court, generating conflict over period-specific limitation application.
One High Court held that consolidation of Show Cause Notices across financial years is permissible, citing statutory phrases permitting notice "for any period" and the practical need to trace fraudulent Input Tax Credit transactions spanning years. Several other High Courts have ruled that consolidation is impermissible because limitation periods apply distinctly to each financial year, requiring separate SCNs. The author contends the cited sub sections relate to serving statements for subsequent periods, not to authorise initial consolidated SCNs, and that proper officers must analyse each supply per financial year to invoke the recovery provisions. (AI Summary)