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IN THE HIGH COURT OF KARNATAKA AT BENGALURU
S.R. KRISHNA KUMAR
Pramur Homes And Shelters – Appellant
Versus
Union Of India Represented Herein By The Secretary Department Of Revenue, Ministry Of Finance, Government Of India, North Block, New Delhi – Respondent
| Table of Content |
|---|
| 1. the parties contest the issuance of a consolidated show-cause notice. (Para 1 , 2 , 4 , 5) |
| 2. the court considered rival submissions on the legality of the notice. (Para 3 , 6) |
| 3. the court's analysis highlighted the requirement for separate notices for each financial year. (Para 7 , 8) |
| 4. the petition is allowed, quashing the consolidated show-cause notice. (Para 9 , 10) |
ORDER :
S.R.KRISHNA KUMAR, J.
In this petition, the petitioner seeks for the following reliefs:
“a) Issue a writ of certiorari or any other appropriate writ, order or direction, quashing the impugned Show-Cause Notice bearing No.GEXCOM/MYS-HPU/GST/ADC/13-2025-26 and DIN:20250957YY00006606D0 dated 30.09.2025 (Annexure-A) issued by the Respondent No.4 – Additional Commissioner of Central Tax, Mysuru Commissionerate, as being wholly without jurisdiction, arbitrary, violative of principles of natural justice, and contrary to the provisions of the CGST/KGST Acts, 2017;
b) Issue a writ of prohibition or any other appropriate writ, order or direction, restraining the Respondents, their officers and subordinates from proceedings further or taking any coercive or adjudicatory steps pursuant to the impugned Show
Composite show-cause notices covering multiple financial years under CGST/KGST Act are illegal as assessments must pertain to individual years, respecting statutory limitations and ensuring natural j....
The court established that the issuance of a consolidated show cause notice covering multiple financial years is impermissible under the GST Act, requiring separate notices for each year to respect j....
The court held that composite assessment orders for multiple financial years violate statutory provisions, emphasizing that each period must have a separate assessment to protect registered persons' ....
Tax authorities must issue separate show cause notices for each financial year under Section 74 of the CGST Act to ensure fairness and compliance with statutory timelines.
Issuing composite notices under the CGST/SGST Act for multiple assessment years is unsustainable as it violates principles of fair adjudication and results in prejudice to taxpayers.
Composite notices under the CGST/SGST Act for multiple assessment years are unsustainable; individual notices must be issued to uphold fairness for taxpayers.
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