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2026 Supreme(Online)(Ker) 20114

IN THE HIGH COURT OF KERALA AT ERNAKULAM
ZIYAD RAHMAN A.A., J
GREIK XAVIER, AGED 53 YEARS – Appellant
Versus
THE DEPUTYCOMMISSIONER (INTELLIGENCE), KERALA STATE GOODS AND SERVICE TAX DEPARTMENT – Respondent


Advocates:
For the Appellants/Petitioners: SMT.BINISHA BABY, SHRI.ARAVIND SREEKUMAR, SMT.SARITHA K.S., SHRI.ARAVIND RAJAGOPALAN MENON, SHRI.ALEX T. THEVARCAD, SHRI.ANIL D. NAIR (SR.)
For the Respondents: SMT.RESHMITHA R CHANDRAN, SR.G.P

Table of Content
1. legal challenge against a composite notice for several financial years. (Para 1)
2. court affirms need for separate notices based on established precedents. (Para 2)

JUDGMENT

This writ petition is submitted by the petitioner challenging Ext.P1 consolidated Show Cause Notice & Ext.P5 order, which was issued by the respondents for multiple financial years namely, 2018- 2019, 2019-2020, 2020-2021, 2021-2022, 2022-2023 and 2023-2024. The main challenge raised against the sustainability of the same is that, issuance of a composite notice for multiple assessment years was found to be not legally sustainable as per the decision rendered by this Court in Joint Commissioner (Intelligence & Enforcement) v. M/s. Lakshmi Mobiles Accessories [ 2025 KHC OnLine 149 ] and Tharayil Medicals v. Deputy Commissioner, Audit Division - IV [2025 VIL

356 KER]

2. After hearing the learned counsel for the petitioner and the learned Standing Counsel for the respondents, I find merits in the said submission, in view of the fact that, such a finding was indeed entered into by the Division Bench of this Court in the decisions referred to above.

In such circumstances, in the light principles laid

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