Dream Infotech Vs State Tax officer (Madras High Court)
The writ petition was filed before the Madras High Court challenging an assessment order dated 29.10.2025 passed by the State Tax Officer. The petition questioned the legality of issuing a single show cause notice and consequential assessment orders by clubbing multiple financial years, namely 2019–20 to 2023–24.
At the admission stage, with the consent of both parties, the writ petition was taken up for final disposal. The petitioner contended that the core issue related to the impermissible “bunching” or “clubbing” of show cause notices and orders for multiple financial years into a single proceeding. It was submitted that this issue had already been conclusively settled by the Madras High Court in its earlier common order dated 21.07.2025 in a batch of writ petitions. In that decision, the Court had clearly held that the GST law permits issuance of a show cause notice only with reference to a specific tax period. If annual returns are filed, the notice must be based on the annual return for that particular financial year. If issued before filing of annual returns, the notice may be based on monthly returns. Crucially, the Court had held that no show cause notice or order can be issued by clubbing more than one financial year, as such action is impermissible in law and without jurisdiction.
