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2026 Supreme(Online)(Ker) 20184

IN THE HIGH COURT OF KERALA AT ERNAKULAM
ZIYAD RAHMAN A.A., J
SEGO FRESCHE – Appellant
Versus
INTELLIGENCE OFFICER, INTELLIGENCE UNIT, SGST DEPARTMENT KOTTAKKAL – Respondent


Advocates:
For the Appellants/Petitioners: SHRI.K.S.HARIHARAN NAIR, SMT.G.REMADEVI, SMT.DIVYA RAVINDRAN, SMT.HARIMA HARIHARAN, SHRI.RAJATH R NATH, SHRI.DHEERAJ SASIDHARAN, SHRI.SREE HARIDEV
For the Respondents: SHRI.ARUN AJAY SHANKAR, G.P

Table of Content
1. petitioner challenges show cause notices for assessment years. (Para 1)
2. court distinguishes between separate and composite notices. (Para 2 , 3)

J U D G M E N T

This writ petition is submitted by the petitioner challenging Ext.P1 series show cause notices pertaining to the period from 2019-2020 to 2024–25.

2. The challenge is raised mainly against 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]

W.A.No. 627/2025.

3. However on going through Ext.P1 series notices, it can be seen that, these notices are not composite notices, but separate notices pertaining to separate assessment orders. As far as the decision in Lakshmi Mobiles and Tharayil Medicals (supra) are concerned, the same dealt with the composite notices and composite orders for multiple assessment years. On going through Ext.P1 series notices, it can be seen that, these are separate notices and hence, the observations made in the aforesaid decisions cannot be made applicable. Moreover, these are only show cause notices and th

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