HC Quashes Composite GST SCN Issued for Multiple Financial Years

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  • Last Updated on 11 June, 2026

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Composite GST Show Cause Notice

Case Details: Banasura Eco Resorts (P.) Ltd. vs. Intelligence Officer-Intelligence Unit-1 [2026] 187 taxmann.com 302 (Kerala)

Judiciary and Counsel Details

  • Ziyad Rahman A.A., J.
  • Smt. G. Mini, P.J. Anilkumar, Satyajith K. Warrier, Harikrishnan K.U., P.S. Sree Prasad, S. Ananthakrishnan, Advs. & A. Kumar, Sr. Adv. for the Petitioner.

Facts of the Case

The petitioner was issued a consolidated show-cause notice along with a summary under GST covering multiple financial years for demands not involving fraud, collusion, or wilful misstatement. It filed a writ petition challenging the composite show cause notice and its summary on the ground that issuing a single consolidated notice for multiple assessment years was legally impermissible. The petitioner contended that, based on binding Division Bench judgments of the Court, the issuance of separate show cause notices for each relevant financial year was a mandatory statutory requirement for proper adjudication. The matter was accordingly placed before the High Court.

High Court Held

The High Court held that the submission made by the petitioner carried merit in view of the binding findings recorded by the Division Bench in earlier judgments. The Court observed that the principles established in those preceding judgments squarely controlled the issue under consideration and necessitated judicial interference under Section 73 read with Section 75 of the CGST Act and the Kerala GST Act. Consequently, the Court determined that the composite show cause notice and its corresponding summary issued under Rule 142 of the CGST Rules and the Kerala GST Rules were procedurally unsustainable, and therefore quashed both the documents. The Court granted liberty to the jurisdictional officer under GST to issue fresh, separate notices for each relevant assessment year in accordance with the law.

List of Cases Reviewed

List of Cases Referred to

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Author: Taxmann

Taxmann Publications has a dedicated in-house Research & Editorial Team. This team consists of a team of Chartered Accountants, Company Secretaries, and Lawyers. This team works under the guidance and supervision of editor-in-chief Mr Rakesh Bhargava.

The Research and Editorial Team is responsible for developing reliable and accurate content for the readers. The team follows the six-sigma approach to achieve the benchmark of zero error in its publications and research platforms. The team ensures that the following publication guidelines are thoroughly followed while developing the content:

  • The statutory material is obtained only from the authorized and reliable sources
  • All the latest developments in the judicial and legislative fields are covered
  • Prepare the analytical write-ups on current, controversial, and important issues to help the readers to understand the concept and its implications
  • Every content published by Taxmann is complete, accurate and lucid
  • All evidence-based statements are supported with proper reference to Section, Circular No., Notification No. or citations
  • The golden rules of grammar, style and consistency are thoroughly followed
  • Font and size that's easy to read and remain consistent across all imprint and digital publications are applied