Composite GST SCN Covering Multiple Years is Invalid: Karnataka High Court

Issue

Whether a single “composite” Show Cause Notice (SCN) issued under Sections 73 or 74 of the CGST/KGST Act can legally club together multiple financial years, tax periods, or block periods into one consolidated demand.

Facts

The Notice: The petitioner received a single, solitary SCN that combined demands for multiple financial years/periods into one document.
The Challenge: The petitioner moved a writ petition to quash the notice, arguing that “bunching” or “clubbing” multiple years into one SCN is a jurisdictional error that violates the year-specific architecture of the GST law.
The Reliance: The petitioner relied on the landmark ruling in Pramur Homes and Shelters v. UOI.

Decision

Adherence to Precedent: The High Court observed that the controversy was squarely covered by the Pramur Homes decision (decided on December 11, 2025).
Year-Wise Specificity: The Court held that the GST framework is intrinsically structured on a financial-year basis. Key milestones—such as the filing of annual returns and the calculation of limitation periods for demands (3 years under Section 73 and 5 years under Section 74)—are strictly tied to each specific financial year.
Illegal & Void: Clubbing multiple years into one notice prevents the calculation of these distinct limitation periods and prejudices the taxpayer’s ability to provide year-wise rebuttals.
Outcome: The composite SCN was declared illegal and without jurisdiction. The notice and all consequential proceedings were quashed.

Key Takeaways for Taxpayers

One Notice, One Year: The GST department cannot bundle multiple years (e.g., 2019-20 to 2023-24) into a single SCN. Each financial year must have its own separate notice to ensure the limitation period for each year is correctly observed.
Limitation Shield: By clubbing years, the Department often tries to “save” time-barred years by bunching them with recent years. This ruling prevents such “jurisdictional overreach.”
Liberty to Department: Note that while the court quashes the “composite” notice, it almost always grants “liberty” to the Department to issue fresh, separate notices for each year, provided they are still within the individual limitation periods for those years.
Strategic Defense: If you receive a bundled SCN, do not ignore it. File a challenge immediately based on this jurisdictional defect before the final order is passed.

HIGH COURT OF KARNATAKA

Century Galaxy Developers Ltd.

Union of India^*

S.R.Krishna Kumar, J.

WRIT PETITION NO. 22633 OF 2024 (T-RES)

DECEMBER 19, 2025

Bharat Raichandani, Raaghul Piraanesh and Chandra Kiran K., Advs. for the Petitioner. Anuparna Bordoloi, CGC, Akash B. Shetty, Adv. and K. Hema Kumar, AGA for the Respondent.

ORDER

1. In this petition, petitioner seeks the following reliefs:

(a)

Issue a writ of certiorari, or a writ or order or direction in the nature of writ of certiorari and set aside the Impugned Notice vide no. ADCOM/ENF/SZ/DCCT-07/INS-06/2023-24 and Reference No. MA290524278146K dated 29.05.2024 (Annexure B) issued by the Respondent No. 4 as bad in law.

(b)

Issue a writ of certiorari, or a writ or order or direction in the nature of writ of certiorari and hold that Impugned Notice vide no. ADCOM/ENF/SZ /DCCT-07/INS-06/2023-24 and Reference No. MA290524278146K dated 29.05.2024 (Annexure B) issued by Respondent No. 4 was without jurisdiction.

(c)

Issue a writ of Mandamus, or a writ or order or direction in the nature of writ of mandamus and direct the Respondent No. 3 to not to proceed further with the Impugned Notice.

(d)

Issue any other direction or grant any other relief, as deemed fit in the facts and circumstances of this case, in the interest of justice.

(e)

Issue a direction to provide for the cost of this petition.

2. Though several contentions have been urged by both sides in support of their respective claims, the issue in controversy between the parties is directly and squarely covered by the judgment of this Court in the case of Pramur Homes and Shelters v. UOI (Karnataka)/WP No.33081/2025 dated 11.12.2025.

3. In the said judgment, this Court formulated two points for consideration, which reads as under:

(i)

Whether clubbing/consolidation/bunching/ combining of multiple tax periods/financial years in a Single/Composite Show cause notice issued under Section 73 / 74 of the CGST/ KGST Act, 2017 is permissible and valid in law?

(ii)

Whether the impugned Show cause notice dated 30.09.2025 issued by the 4^th respondent to the petitioner for the tax periods/financial years from 2019-20 to 2023-24 under Section 74 of the CGST/ KGST Act, 2017 warrants interference by this Court in the present petition?

4. Issue No.1 was answered by this Court in favour of the petitioner by holding as under:

Point No.(i) is accordingly answered in favour of the petitioner/tax payer/assessee by holding that clubbing/ consolidation/ bunching/ combining of multiple tax periods/financial years in a Solitary/Single/Composite Show cause notice issued under Section 73/74 of the CGST/KGST Act is illegal, invalid, impermissible and without jurisdiction or authority of law and contrary to the provisions of the CGST/KGST Act.

5. So also point No.2 was also answered by this Court in favour of the petitioner by quashing the impugned Show Cause Notice by holding as under:

“Re: Point No.(ll);

9. While dealing with Point No. (i) supra, I have already come to the conclusion that clubbing / consolidation / bunching/ combining of multiple tax periods/financial years in a Solitary/Single/Composite Show cause notice issued under Section 73 / 74 of the CGST / KGST Act is illegal, invalid, impermissible and without jurisdiction or authority of law and contrary to the provisions of the CGST / KGST Act. In the instant case, a perusal of the impugned Show cause notice dated 30.09.2025 will indicate that the same encompasses and pertains to multiple tax periods/financial years, viz., from 2019-20 to 2023-24, which is impermissible in law and consequently, the impugned Show cause notice and all further proceedings pursuant thereto are also vitiated and deserve to be quashed reserving liberty to the respondents to initiate any action/proceedings in accordance with law.

Polnt No.(ll) is also accordingly answered in favour of the petitioner/tax payer/assessee by holding that the impugned Show cause notice dated 30.09.2025 issued by the 4^th respondent to the petitioner for the tax periods/financial years from 201920 to 2023-24 under Section 74 of the CGST/KGST Act is illegal, invalid, impermissible, arbitrary and without jurisdiction or authority of law and contrary to the provisions of the CGST/KGST Act and the impugned show cause notice and all further proceedings, orders, notices pursuant thereto deserve to be quashed by reserving liberty in favour of the respondents to initiate proceedings in accordance with law.

10. In the result, I pass the following:

ORDER

(i)

Petition is hereby allowed.

(ii)

The impugned show-cause notice at Annexure-A dated 30.09.2025 issued by respondent No.4 and all further proceedings, orders, notices etc., pursuant thereto initiated/to be initiated by the respondents are hereby quashed.

(iii)

The respondents are however reserved liberty to initiate appropriate proceedings in accordance with law and if such proceedings are initiated by the respondents, petitioner would be entitled to contest / defend the same in accordance with law.”

6. The issue in controversy involved in the present petition also relates to clubbing /consolidation/ bunching/combining of multiple tax periods/financial years/block periods in a Single/Composite Show cause notice, which has already been held to be invalid and illegal by this Court in Pramur Homes and Shelters’s case referred to supra.

7. Under these circumstances, the impugned show cause notice dated 29.05.2024 at Annexure-B passed by respondent No.4 deserve to be quashed.

8. In the result, I pass the following:

ORDER

(i)

Petition is hereby allowed and disposed of in terms of Pramur Homes and Shelters (supra).

(ii)

The impugned show cause notice dated 29.05.2024 at Annexure-B passed by respondent No.4 and all further proceedings, orders, notices etc., pursuant thereto initiated/to be initiated by the respondents are hereby quashed.

(iii)