ORAL ORDER

In this petition, petitioner challenges the impugned show cause notice dated 03.05.2024 at Annexure – D and the order dated 21.11.2023 at Annexure – B issued by the respondent for the tax periods 2017-18, 2018-19, 2019-20 and 2020-21. The petitioner contends that these notices, issued under Section 73 of the Central Goods and Services Tax (CGST) Act, 2017, are flawed due to the improper consolidation of multiple tax periods into a single show cause notice.

2. The petitioner’s primary argument is that the respondent cannot issue a common show cause notice by grouping the tax periods from 2017-18 to 2020-21. The petitioner asserts that under Section 73 of the CGST Act, a specific action must be completed within the relevant year, and the limitation period of three years applies separately to each assessment year. Consequently, the petitioner contends that clubbing multiple tax periods in a single notice is impermissible, and separate notices should have been issued for each assessment year under sub-

Section (1) of Section 73.

3. The petitioner relies on the judgment of the Hon'ble Madras High Court in the case of M/s. Titan Company Ltd. vs. Joint Commissioner of GST1. The Ma