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2026 Supreme(Online)(Ker) 30883

IN THE HIGH COURT OF KERALA AT ERNAKULAM
Ziyad Rahman A.A., J
Capital Signage – Appellant
Versus
Deputy Commissioner (Intelligence) – Respondent


Advocates:
For the Appellants/Petitioners: K.S. Hariharan Nair, G. Remadevi, Gopalakrishnan Nair P.N., Harima Hariharan, Rajath R Nath, Dheeraj Sasidharan
For the Respondents: Arun Ajay Shankar

Table of Content
1. consolidated notices for multiple assessment years are procedurally invalid under tax law. (Para 1 , 2)

JUDGMENT

This writ petition is submitted by the petitioner challenging Ext.P1 consolidated Show Cause Notice which was issued by the respondents for multiple financial years namely, April, 2019 to March, 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 (M/s.), Thrissur v. Deputy Commissioner, Thrissur [2025 KHC OnLine 467].

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 of the principles laid down by this Court in the above referred judgments, an interference is required. Accordingly, this writ

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