Kota Metals & Anr. Vs Additional Commissioner (Adjudication) & Ors. (Rajasthan High Court)
The Rajasthan High Court considered a writ petition challenging a show cause notice issued under Section 74 of the Central Goods and Services Tax Act, 2017 for the financial years 2018-19 to 2023-24 through a single notice. The petitioners also challenged the adjudication order, which had been passed collectively for all the years covered by the notice.
The petitioners contended that issues such as limitation, cross-examination, and the availability of benefits from one year to another required separate examination for each assessment year. It was argued that the issuance of a common notice covering multiple years was itself bad in law. Reliance was placed on interim orders passed by the Rajasthan High Court in earlier cases, where similar notices covering multiple years were found prima facie erroneous and interim protection had been granted.
The Court issued notice to the respondents. Counsel appearing for respondent Nos. 1 to 4 and respondent Nos. 5 and 6 accepted notice, and service was treated as complete. The Court directed the respondents to file their reply to the writ petition within four weeks and ordered that the matter be listed thereafter.
As an interim measure, the Court stayed the effect and operation of the adjudication order dated 12.09.2025 passed under Section 74 of the CGST Act pending further consideration of the matter.
