Tag Archives: Deputy Commissioner of State Tax

Composite Show Cause Notice and Assessment Order Encompassing Multiple Assessment Years Are Invalid in Law

By | September 30, 2026

Composite Show Cause Notice and Assessment Order Encompassing Multiple Assessment Years Are Invalid in Law Issue Whether a composite Show Cause Notice (SCN), summary notice (DRC-01A), and assessment order issued under Section 73 covering multiple tax periods/assessment years (FY 2019–20 to FY 2023–24) are legally sustainable. Facts Composite Proceedings: The 1st respondent issued a single,… Read More »

Voluntary GST payment via DRC-03 during search cannot be challenged as coercive after prolonged silence.

By | July 17, 2026

Voluntary GST payment via DRC-03 during search cannot be challenged as coercive after prolonged silence. Issue Whether tax dues deposited via Form GST DRC-03 during a search operation can be challenged as a coercive recovery through a writ petition after a two-year delay without any contemporaneous complaint. Whether the delayed issuance of an acknowledgment in… Read More »

Composite Show Cause Notice and Adjudication Order Covering Multiple Assessment Years Is Legally Impermissible

By | June 12, 2026

Composite Show Cause Notice and Adjudication Order Covering Multiple Assessment Years Is Legally Impermissible Issue Whether the Revenue can issue a single, composite Show Cause Notice (SCN) and subsequent adjudication order under Section 73 spanning multiple financial years, or if tax periods must be initiated and adjudicated separately for each individual assessment year. Facts The… Read More »