HC Quashes Consolidated GST SCN for Multiple Years

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  • Last Updated on 8 April, 2026

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GST Consolidated SCN

Case Details: Shree Balaji Traders vs. GST Commissioner - [2026] 184 taxmann.com 701 (Bombay)

Judiciary and Counsel Details

  • Anil L. Pansare & Nivedita P. Mehta, JJ.
  • Shyam Dewani & Sahil Dewani, Advs. for the Petitioner.
  • Ms P. D. Rane, Adv. for the Respondent.

Facts of the Case

The petitioner challenged a consolidated show cause notice (SCN) issued by the jurisdictional officer under CGST, invoking fraud, covering multiple financial years and tax periods. The notice alleged suppression of taxable value, leading to short payment and applied mutatis mutandis to the Maharashtra GST Act and the IGST Act, while clubbing distinct tax periods and financial years into a single proceeding. The petitioner contended that such consolidation was impermissible under the GST framework, which operates on year wise assessment with separate annual returns, distinct limitation periods, and defined tax periods for each financial year. It was further contended that invoking fraud provisions only extends limitation and does not permit issuance of a consolidated notice across financial years. The matter was accordingly placed before the High Court.

High Court Held

The High Court held that the issuance of a consolidated SCN covering multiple financial years and tax periods was impermissible under Section 74 of the CGST Act. It held that the GST scheme mandates year wise determination of tax liability, with distinct annual returns, separate limitation for each financial year, and clearly defined tax periods, which cannot be merged through a single notice. The Court further held that allegations of fraud or suppression do not create any exception to this requirement, but only extend the limitation period to five years from the due date of furnishing the annual return for each respective year. Accordingly, the impugned notice was quashed, and the Department was permitted to proceed afresh by issuing distinct notices for each financial year.

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