The court upheld that consolidated show cause notices are permissible under the CGST Act and that e-mail serves as adequate notice under the relevant provisions.

JUDGMENT :

1. This hearing has been done through hybrid mode. 

CM APPL. 49692/2025 
2. Allowed subject to all just exceptions. Accordingly, the application is disposed of. 

CM APPL. 49694/2025 
3. This is an application for condonation of delay in refiling. For the reasons stated in the application, the delay is condoned. Application is disposed of. 

W.P.(C) 12199/2025 & CM APPL. 49693/2025 
4. The present petition has been filed by the Petitioner under Article 226 of the Constitution of India, inter alia, challenging the following: 

5. Mr. Rajeev Aggarwal, ld. Counsel for the Petitioner submits that insofar as the first order dated 16th January, 2025 is concerned, the Petitioner  is willing to prefer an appeal as the ground raised in this matter in respect of  the said order is that it is being issued for multiple years. This issue now stands  covered by decision of this this Court in Ambika Traders through Proprietor  Gaurav Gupta v. Additional Commissioner, Adjudication DGGSTI, CGST  Delhi North, 2025:DHC:6181-DB, where the Court has held as under:  

“Consolidated SCN for Multiple Financial Years 
43. Insofar as the issue of consolidated notice for various financial years is concerned, a perusal of Section 74 of the CGST Act would itself show that at least insofar as fraudulently availed or utilized ITC is concerned, the language used in Section 74(3) of the CGST Act and Section 74(4) of the CGST Act is “for any period” and “for such periods” respectively. This contemplates that a notice can be issued for a period which could be more than one financial year. Similar is the language even in Section 73 of the CGST Act. The relevant provisions read as under: 
“73. Determination of tax [, pertaining to the period up to Financial Year 2023-24,] not paid or short paid or erroneously refunded or input tax credit wrongly availed or utilised for any reason other than fraud or any wilful-misstatement or suppression of facts.–– 
xxx xxx xxx 
(3) Where a notice has been issued for any period under sub-section (1), the proper officer may serve a statement, containing the details of tax not paid or short paid or erroneously refunded or input tax credit wrongly availed or utilised for such periods other than those covered under sub-section (1), on the person chargeable with tax. 
(4) The service of such statement shall be deemed to be service of notice on such person under sub-section (1), subject to the condition that the grounds relied upon for such tax periods other than those covered under subsection (1) are the same as are mentioned in the earlier notice. 
xxx xxx xxx 
74. Determination of tax [, pertaining to the period up to Financial Year 2023-24,] not paid or short paid or erroneously refunded or input tax credit wrongly availed or utilised by reason of fraud or any wilful-misstatement or suppression of facts.–– 
xxx xxx xxx 
(3) Where a notice has been issued for any period under sub-section (1), the proper officer may serve a statement, containing the details of tax not paid or short paid or erroneously refunded or input tax credit wrongly availed or utilised for such periods other than those covered under sub-section (1), on the person chargeable with tax. 
(4) The service of statement under sub-section (3) shall be deemed to be service of notice under sub-section (1) of section 73, subject to the condition that the grounds relied upon in the said statement, except the ground of fraud, or any wilful-misstatement or suppression of facts to evade tax, for periods other than those covered under sub-section (1) are the same as are mentioned in the earlier notice.” 

44. Some of the other provisions of the CGST Act, which are relevant, include Section 2(106) of the CGST Act, which defines “tax period” as under: 

“2.[…] (106) “tax period” means the period for which the return is required to be furnished” 
45. Thus,