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2025 Supreme(Online)(Mad) 45201

IN THE HIGH COURT OF JUDICATURE AT MADRAS
JUSTICE, J
Smt R Ashaarajaa Partner of M/s JRD Realtorss – Appellant
Versus
THE SENIOR INTELLIGENCE OFFICER – Respondent


Advocates:
For the Appellants/Petitioners: Mr.Abdul Hameed, Mr.Srinath Sridevan, Mr.P.V.Balasubramaniam, Mr.G.Natarajan, Mr.Joseph Prabakar
For the Respondents: Mr.AR.L.Sundaresan

COMMON ORDER

All these writ petitions have 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. As the issue involved in all these Writ Petitions is identical in nature and the relief sought thereunder is interconnected, they were heard together and disposed of vide this Common Order.

3. Petitioners' submissions:

3.1 Mr.Abdul Hameed, Mr.Srinath Sridevan & Mr.P.V.Balasubramaniam, learned Senior counsel and Mr.G.Natarajan & Mr.Joseph Prabakar, learned counsel had appeared for the respective petitioners.

3.2 The learned Senior counsel appearing for the respective petitioners would submit that the bunching of Show Cause notice for more than one financial year is bad in law and against the principles of natural justice and also it will prejudice the interest of an assessee.

3.3 Further, they 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

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