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

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

• Pramur Homes and Shelters v. Union of India [2025] 181 taxmann.com 541 (Karnataka) (para 5), followed

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).