Composite show cause notices under GST for multiple assessment years are invalid; separate notices required per year.

JUDGMENT

This writ petition is submitted by the petitioner challenging Ext.P1 consolidated show cause notice issued by the Joint Commissioner (Intelligence & Enforcement), State GST Department, Ernakualm for multiple financial years namely, 2018-19 to 2022-23 and Ext.P2 order-in-original and Ext.P3 summary order passed by the respondent. 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 decisions rendered 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].

2. After hearing the learned counsel for the petitioner and the learned Government Pleader for the respondent, 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 of the principles laid down by this Court in the above referred judgments, an interference is required. Accordingly, this writ petition is disposed of, quashing Exts.P1, P2 and P3, granting liberty to the respondent to issue separate notices for the relevant assessment years. However, the period from the date of Ext.P2 till the date of receipt of the certified copy of the judgment, shall be excluded while computing the period of limitation for initiating fresh proceeding. All other contentions are left open.