S.R.S Travels And Logistics Private Limited Vs Additional Director of GST Intelligence (Karnataka High Court)
The Karnataka High Court considered a writ petition challenging a show cause notice dated 21.06.2024 and an Order-in-Original dated 03.02.2025 issued under the GST law, whereby proceedings were initiated for reversal of input tax credit for the period from 2019–20 to 2021–22 (up to July). The petitioner sought quashing of both the notice and the adjudication order, contending that the proceedings were vitiated in law.
The Court noted that although several contentions were raised by both sides, the controversy involved was directly and squarely covered by an earlier judgment of the same Court in Pramur Homes and Shelters v. Union of India, decided on 11.12.2025. In that decision, the Court had framed two key issues: first, whether clubbing or consolidation of multiple tax periods or financial years into a single composite show cause notice under Sections 73 or 74 of the CGST/KGST Acts was permissible; and second, whether such a composite show cause notice warranted judicial interference.
In Pramur Homes and Shelters, the Court answered both issues in favour of the taxpayer. It held that clubbing, consolidation, bunching, or combining of multiple tax periods or financial years in a solitary or composite show cause notice under Sections 73 or 74 of the CGST/KGST Acts is illegal, invalid, impermissible, and without jurisdiction or authority of law. The Court further held that a show cause notice covering multiple tax periods is contrary to the statutory scheme and vitiates all proceedings initiated pursuant to such notice. Consequently, the impugned show cause notice in that case was quashed, while liberty was reserved to the authorities to initiate fresh proceedings in accordance with law.
