Composite SCN for Multiple Years Under Section 73 Invalid | HC

Case Details: Tvl. Shot X Retail (P) Ltd vs. State Tax Officer (ST) [2026] 182 taxmann.com 771 (Madras)

Judiciary and Counsel Details

• Krishnan Ramasamy, J.
• Sudalai Muthu N. for the Petitioner.
• R.Suresh Kumar, AGP for the Respondent.

Facts of the Case

The petitioner challenged the assessment order passed by the State Tax Officer pursuant to a single composite show cause notice (SCN) covering multiple financial years. The impugned order adjudicated demands in one consolidated proceeding. The petitioner relied on an earlier common order on an identical issue and contended that clubbing of adjudications for multiple financial years into one show cause notice and one assessment order was impermissible in law and rendered the assessment without jurisdiction. The matter was accordingly placed before the High Court.

High Court Held

The High Court held that the impugned order covered more than one financial year. Such clubbing was without jurisdiction and impermissible in law under Section 73 of the CGST Act. The Court held that the composite assessment could not be sustained and that the impugned assessment and consequential orders were to be quashed. The Court set aside the composite SCN with liberty to initiate separate proceedings for each financial year.

List of Cases Reviewed

• Smt. R. Ashaarajaa v. Senior Intelligence Officer, Directorate General Of GST Intelligences [2025] 176 taxmann.com 689/111 GST 91/101 GSTL 10 (Mad) (Para 9) followed

List of Cases Referred to

• Smt. R. Ashaarajaa v. Senior Intelligence Officer, Directorate General Of GST Intelligences [2025] 176 taxmann.com 689/111 GST 91/101 GSTL 10 (Mad) (para 5).