The Hon’ble Supreme Court in Joint Commissioner (Intelligence and Enforcement) & Anr. issued notice in the Special Leave Petition filed by the Revenue, thereby agreeing to examine the vexed question as to “whether a consolidated SCN and adjudication order covering multiple financial years can be issued under Section 74 of the CGST Act.
Multiple High Courts across the country have now drawn a firm line against the practice of issuing composite or consolidated SCNs and assessment orders spanning multiple financial years / tax periods under Sections 73 and 74 of the CGST Act.
The Hon’ble Delhi High Court in the case of M/s. Technosys Integrated Solutions Pvt Ltd held that consolidation of multiple financial years in a single Show Cause Notice (SCN) and adjudication order is permissible under Sections 73 and 74 of the CGST Act, even in cases not involving fraudulent Input Tax Credit, and declined interference in writ jurisdiction in view of the availability of an alternate appellate remedy.
The Hon’ble Karnataka High Court (Division Bench) in The Commissioner of Central Tax allowed the intra-court appeals filed by the Revenue, setting aside the orders of the learned Single Judge ..
The Hon’ble Bombay High Court in M/s Rollmet LLP & Ors examined a batch of writ petitions challenging the legality of single consolidated show-cause notices issued under Sections 73/74 of the CGST Act covering multiple financial years.
The Hon’ble Madras High Court in the case of Radiant Cash Management Services Ltd. held that there is no statutory bar under the GST enactments for issuance of multiple SCNs under Section 73 for the same tax period if they address different discrepancies..
The Hon’ble Supreme Court in the case of Mathur Polymers upheld the Delhi High Court judgment [W.P.(C) 2394/2025 & CM APPL. 11289/2025, order dated August 26, 2025] which held that consolidated SCN covering multiple financial years are permissible in cases of fraudulent Input Tax Credit (ITC) availment, and service of notice on the registered email address constitutes valid service under Section 169(1)(c) of the CGST Act.
The Hon’ble Karnataka High Court in Emmanuel Constructions (P.) Ltd. quashed a consolidated SCN and demand orders issued for FY 2019-20 & 2020-21, citing non-conformity with the provisions of the CGST Act
THE HON’BLE KARNATAKA HIGH COURT IN THE CASE OF Albatross Builders and Developers LLP V/s Assistant Commissioner of Central Tax (A.E.),decided on 14-11-2024
The Office of the Commissioner of the Commercial Taxes Telangana State -Hyderabad issued Standard Operation Procedure (SOP) In pursuance to the proceedings of the Hon’ble High Court of Telangana in WP No.20731 & 24077 of 2025 dt. 08.09.2025.
