ORDER

Date : --

1. Heard Mr. Rajeev Channappa Nulvi, learned counsel for the for the petitioner.

2. This application under Article 226 of the Constitution of India has been filed by the petitioner, namely M/s Pugos Products Private Ltd., impugning the Order In Original dated 18.12.2025, bearing Order No. In Original/AC/AIZAWL-CGST-DIV/GST/No. 18/25-26, passed under Section 74(9) of the Central Goods and Services Tax Act, 2017.

3. It is the contention of the writ petitioner that respondent No. 2 has issued a Demand-cum-Show Cause Notice for the financial years 2018–2019, 2019–2020, 2020–2021, 2021–2022, and 2022–2023. Learned counsel for the petitioner has submitted that, under Section 74(10) of the Central Goods and Services Tax Act, 2017, a combined Demand-cum-Show Cause Notice cannot be issued for multiple tax periods, as has been done in the present case.

4. He submits that, in this regard, several High Courts have held that show cause notices issued by the authorities for multiple tax periods are fundamentally flawed, and that issuing a single consolidated show cause notice for multiple tax periods contravenes the provisions of the GST Act and establishes legal precedents. In support of his submission, the learned counsel for the petitioner has relied upon the ruling of the High Court of Karnataka in the case of “Bangalore Golf Club Vs. Assistant Commissioner of Commercial Taxes, in [WP(C) No. 16500 of 2024, order dated 07.08.2024]. He has also cited a ruling of the Kerala High Court in the Case of “Joint Commissioner (Intelligence & Enforcement) and Another Vs. M/S Lakshmi Mobile Accessories, (WA No. 258 of 2025)

5. Issue notice to the respondents

6. It appears from the Office Note dated 08.04.2026 that the notice, along with a copy of the writ petition, has already been served on respondent Nos. 1 to 3.

7. Let this matter be listed again on 18.05.2026.

8. In the meanwhile, considering the submissions made by the learned counsel for the petitioner, as discussed in the foregoing paragraphs, and as it, prima facie, appears that the impugned Show Cause Notices contravene the provisions of Section 74(10) of the Central Goods and Services Tax Act, 2017, the impugned order as well as the Demand-cum-Show Cause Notices issued to the present petitioner, namely, [Order No. In Original/AC/AIZAWL-CGST-DIV/GST/No. 18/25-26, passed under Section 74(9) of the Central Goods and Services Tax Act, 2017], as well as the impugned Demand-cum-Show Cause Notice No. 5 bearing DIN: 2025670UY000000EB71 dated 13.06.2025, along with GST Form DRC-07 dated 19.12.2025 bearing Reference No. ZD151225000185Z shall remain stayed till the next date fixed.

9. List accordingly.