Ludna reviewed-Held - As could be seen, the Division Bench has in categorical terms held that there is no scope for consolidating various financial years/tax period while issuing show cause notice under Section 74 of the CGST Act, 2017.

The Counsel for respondent nos. 1 and 2 has invited our attention to a communication dated 15/9/2025 issued by the Under Secretary to the Govern.....

Held - It is the case of the petitioner that the issue is sub judice before the Apex Court and also the Apex Court in the matter of M/S Aparna Collection Vs. Union Of India in WP(C) No. 890/2025 has granted liberty to the petitioner to approach this Court, in light of the decisions of the Madras High Court and the High Court of Andhra Pradesh on the said issue which accordi.....

Held - On a plain reading of the provisions, we find it difficult to accept that the intention of the legislature in providing for sub-section (1) of Section 73/74 was to confine the authority of the proper officer to a issue show cause notice not for the different periods but for a specific period for which one return could be filed. This prima facie is clear from the plain language of the provisions and.....

Held - This Court shall also deal with the submission advanced by Mr. Rastogi that the decision of this Court in Ambika Traders (Supra) does not govern the present case on the ground that the said judgment arose in the context of fraudulent availment or utilisation of ITC extending across financial years. 

As already observed he.....

Held - The issue involved is covered by a judgment passed by the Division Bench of this Court at Goa in M/s. Milroc Good Earth Developers Vs. Union of India & Ors. [Writ Petition No. 2203/2025 decided on 9/10/2025], wherein, the Court held that if an authority lacks jurisdiction to have composite assessment for different tax periods/assessment years, then the formality of responding to&nbs.....

 Held - We find no good ground and reason to interfere with the impugned judgment/order passed by the High Court.

The special leave petition is, accordingly, dismissed.

Pending application(s), if any, shall stand disposed of.