ORDER

This writ petition has been filed challenging the issue with regard to the “bunching of Show Cause notices”, i.e., issuance of a single show cause notice, by the respondents, for more than one financial year.

2. Petitioners' submissions:

2.1 The learned counsel for the petitioner would submit that in this case, the respondent had issued a single show cause notice and thereafter, passed a single assessment order for 6 financial years, viz., 2017-18, 2018-19, 2019-20, 2020-21, 2021-22 & 2022-23.

2.2 Further, he would submit that the Good and Services Tax Act, 2017, (hereinafter called as “GST Act”) fixes the limitation for issuance of notices and passing the assessment orders for each and every financial years under section 73 and 74 of the GST Act. When such being the case, the notice under said Sections shall be issued to the Assessee separately for each financial year. Hence, he would contend that the bunching of notice for more than one financial year is against the spirit of section 73 and 74 of GST Act.

2.3 He would also submit that while bunching, the show cause notices were issued at the fake end of the limitation period, due to which, the petitioner may not be able to colle