Single SCN for Multiple Tax Periods Invalid Under GST Law | HC

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Single SCN multiple tax periods

Case Details: MCR Marketing vs. Assistant Commissioner of Central Tax [2026] 183 taxmann.com 326 (Karnataka)

Judiciary and Counsel Details

  • S. Sunil Dutt Yadav, J.
  • Rajeev Channappa Nulvi, Adv. for the Petitioner.
  • Shishira Amarnath, Adv. for the Respondent.

Facts of the Case

In the instant case, the petitioner was issued a single show cause notice for the tax periods spanning from 2017-18 to 2021-22. The petitioner contended that a single show cause notice for multiple tax periods is impermissible.

High Court Held

The Karnataka High Court held that the issue in controversy relating to clubbing/consolidation/bunching/combining of multiple tax periods in a single/composite show cause notice has already been settled by the co-ordinate Bench in Pramur Homes and Shelters v. Union of India [2025] 181 taxmann.com 541 (Karnataka). The order of adjudication is passed for a year. The tax period in the instant case spanned from 2017-2018 to 2021-2022. In light of the decision in Pramur Homes and Shelters (supra), the show cause notice issued was defective.

List of Cases Reviewed

List of Cases Referred to

  • Lakshmi Venkateshwara Traders MS Scrap v. Deputy Commissioner of Central Tax [W.P. No. 22726 of 2025, dated 17-12-2025] (para 3)
  • Pramur Homes and Shelters v. Union of India [2025] 181 taxmann.com 541 (Karnataka) (para 3).

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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