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2026 Supreme(Online)(Ker) 10605

IN THE HIGH COURT OF KERALA AT ERNAKULAM
MR. ZIYAD RAHMAN A.A., J
DHANLAXMI BANK LIMITED – Appellant
Versus
STATE OF KERALA – Respondent


Advocates:
For the Appellants/Petitioners: SHRI.ABRAHAM JOSEPH MARKOS, SRI.ISAAC THOMAS, SHRI.ALEXANDER JOSEPH MARKOS, SHRI.JOHN VITHAYATHIL, SRI.V.ABRAHAM MARKOS
For the Respondents: SRI. MOHAMMED RAFIQ, GOVT. PLEADER, SRI. P.T.DINESH, SC

Table of Content
1. introduction to the case and its background regarding notices issuance. (Para 1)
2. arguments presented by both petitioners and respondents regarding the nature of composite notices. (Para 2 , 3 , 4 , 5 , 6)
3. court's analysis of the prejudices caused to taxpayers due to composite notices. (Para 8)
4. discussion on the binding nature of previous judgments and implications for future cases. (Para 9 , 10 , 11)

JUDGMENT

The common issue that arises in all these writ petitions is relating to the sustainability of the notices issued under Sections 73 and 74 of the CGST/SGST Act 2017 in the form of a composite notice for multiple assessment years. The learned counsel appearing for the petitioners contend that the issues raised regarding the composite notice and order is already decided by a Division Bench of this Court in M/s.Lakshmi Mobile Accessories v. Joint Commissioner (Intelligence & Enforcement) [ 2025 KHC OnLine 149 ] and Tharayil Medicals v. The Deputy Commissioner [2025 KHC Online 467]. However, the contention of the learned Government Pleader for the State of Kerala as well as the Senior Panel counsel appearing for the Central Government is that, there is no pro

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