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IN THE HIGH COURT OF JUDICATURE AT MADRAS
C.SARAVANAN
Radiant Cash Management Services Ltd, Represented by it Chairman & Managing Director – Appellant
Versus
Commercial Tax Officer, Office of the Assistant Commissioner (ST), Pondy Bazaar Assessment Circle, Chennai – Respondent
| Table of Content |
|---|
| 1. jurisdiction of tax notices. (Para 1 , 2 , 3 , 6 , 8) |
| 2. procedural history of tax assessments. (Para 4 , 5 , 7) |
| 3. details and issues raised in the show cause notices. (Para 9 , 10 , 12 , 13 , 14 , 20) |
| 4. arguments against multiple assessments. (Para 17 , 18 , 19 , 33 , 39) |
| 5. judicial interpretation on assessment overlap. (Para 22 , 23 , 24 , 28 , 29) |
| 6. limits of legal precedent in tax matters. (Para 30 , 31 , 32) |
| 7. finality of proceedings under gst. (Para 34 , 48) |
| 8. conclusion of the writ petition. (Para 49 , 50 , 51) |
ORDER :
C.SARAVANAN, J.
The Petitioner is before this Court against the impugned Show Cause Notice in FORM GST DRC 01 dated 23.09.2025 issued under Section 73 of the respective GST Enactments by the Respondent for the tax period 2021-2022.
2.In the impugned Show Cause Notice in DRC 01 dated 23.09.2025, the timeline prescribed for personal hearing and due date to file reply are as follows:-
3.The impugned Show Cause Notice in DRC 01 dated 23.09.2025 is pursuant to an intimation in Form GST ASMT 10 dated 22.08.2025 issued by the Respondent for the tax period 2021-2022, wherein the Petitioner was called upon by the Respondent to file a reply on or before 21.
Multiple Show Cause Notices can exist for the same tax period under GST if they pertain to different subjects, reinforcing the absence of a bar under the GST regulations.
Natural justice is upheld when multiple opportunities to be heard are provided; consolidated orders across tax periods are permissible under CGST law without causing prejudice unless demonstrable har....
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 main legal point established in the judgment is the mandatory and imperative nature of the show cause notice requirement under Section 74(1) of the JGST Act and the need for specific charges in t....
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