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2026 Supreme(Online)(Ker) 20183

IN THE HIGH COURT OF KERALA AT ERNAKULAM
ZIYAD RAHMAN A.A., J
SIFAR METALS – Appellant
Versus
UNION OF INDIA – Respondent


Advocates:
For the Appellants/Petitioners: DR.K.P.PRADEEP, SRI.T.T.BIJU, SMT.SMITHA GOPINATH, SMT.T.THASMI, SMT.M.J.ANOOPA, SMT.POOJA V.M.
For the Respondents: SRI.SREELAL N.WARRIER, SRI.V.GIRISHKUMAR

Table of Content
1. challenge against composite notice (Para 1)
2. judgment on sustainability of notices (Para 2)

JUDGMENT

This writ petition is submitted by the petitioner challenging Ext.P3 Show Cause Notice and Ext.P4 Order. The challenge is raised mainly on the ground that, the said notice and the order are the composite notice/order for multiple assessment years, pertaining to 2017-18 to 2019- 20. One of the main contentions raised by the petitioner is that, in the light of the law laid down by this Court in Joint Commissioner (Intelligence & Enforcement) v. M/s. Lakshmi Mobiles Accessories [ 2025 KHC OnLine 149 ] and Tharayil Medicals (M/s.), Thrissur v. Deputy Commissioner, Thrissur [2025 KHC OnLine 467], the said notice and order are unsustainable.

2. After hearing the learned counsel for the petitioner, the learned Standing Counsel appearing for respondents, I find merit 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. Thus, in the light of the principles laid down in the said decisions, such composite notice and order for multiple assessment years are not sustainab

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