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2026 Supreme(Ker) 575

IN THE HIGH COURT OF KERALA AT ERNAKULAM
ZIYAD RAHMAN A.A.
Dhanlaxmi Bank Limited – Appellant
Versus
State Of Kerala, Represented By The Secretary – Respondent


Advocates Appeared:
For the Appellant : ADVS. SHRI.ABRAHAM JOSEPH MARKOS SRI.ISAAC THOMAS SHRI.ALEXANDER JOSEPH MARKOS SHRI.JOHN VITHAYATHIL SRI.V.ABRAHAM MARKOS
For the Respondent: SHRI.MOHAMMED RAFIQ, SPL.G.P, SHRI.P.R.SREEJITH, SC, SHRI.P.T.DINESH, SC

Table of Content
1. overview of the writ petitions (Para 1)
2. discussion on the composite notice mechanism (Para 2 , 3 , 4 , 5 , 6 , 8 , 9)
3. court's adherence to precedent (Para 10 , 11)

JUDGMENT :

ZIYAD RAHMAN A.A., J.

1. 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 Joint Commissioner (Intelligence & Enforcement) v. M/s. Lakshmi Mobile Accessories [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 prohibition in the Act, against the issuance of a composite notice for multiple assessment years and the decisions rendered by the Delhi High Court upholding the validity of such notices were already upheld by the Honour

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