Edge Solutions Vs Joint Commissioner of Central Tax (Karnataka High Court)
The Karnataka High Court considered a writ petition challenging a show cause notice dated 01.02.2021 and a consequent order dated 20.06.2022 passed under Section 74 of the Central Goods and Services Tax Act, 2017, covering the tax periods from July 2017 to March 2020. The petitioner sought quashing of the proceedings, contending that the authorities had illegally clubbed multiple tax periods into a single, composite show cause notice.
The Court noted that although several arguments were raised, the controversy was directly covered by its earlier judgment in M/s Pramur Homes and Shelters vs. Union of India, decided on 11.12.2025. In that decision, the Court had categorically held that clubbing, consolidation, or bunching of multiple tax periods or financial years into one composite show cause notice under Sections 73 or 74 of the CGST/KGST Acts is illegal, impermissible, and without jurisdiction. The Court had further quashed such composite notices while reserving liberty to the tax authorities to initiate fresh proceedings in accordance with law.
Applying the same legal position, the Court held that the issue in the present petition was identical, as the impugned notice and order were also based on a consolidated approach covering multiple tax periods. Consequently, the Court allowed the petition, quashed the show cause notice dated 01.02.2021 and the order dated 20.06.2022, along with all consequential proceedings.
