Order dated 21 July 2025 
Parties:  Smt. R. Ashaarajaa v. Senior Intelligence Officer, DGGI & Ors.

Facts -

• The petitioner challenged a show cause notice dated 31.07.2024 (read with Form GST DRC-01 dated 02.08.2024) issued under Section 74 of the GST Act. The notice sought to club multiple assessment years (2017–18 to 2021–22) into a single proceeding. 
•  The petitioner contended that such "bunching" was arbitrary, violated natural justice, and contravened statutory timelines.

Issue -

• Whether a consolidated SCN and assessment covering multiple financial years is valid under Section 73 and 74 of the GST Act?

Order -

• The single bench of Hon’ble high court observed that when a notice was issued and order was passed under Section 74 of the GST Act by clubbing more than one financial year, where the case was made out for any particular tax period and there is a scope to set aside the said order for remaining tax period, the petitioners’ right to contest the matter pertaining to any particular tax period under Section 73 of the GST Act will get affected since the department will look into the said matter from the perspective of commission of offence under Section 74 of the GST Act for all the years mentioned in the notice when it was intact committed only particular financial year.
• In these cases, without any jurisdiction, the impugned show cause notices/orders came to be issued/passed for more than one financial year, which is impermissible in law and hence, the same is liable to be quashed