KAL Media Services Pvt Ltd Vs Joint Commissioner of Central Taxes (Madras High Court)
In a recent writ petition filed by KAL Media Services Pvt Ltd, the Madras High Court has quashed tax notices issued by the Joint Commissioner of Central Taxes. The court’s decision hinged on a procedural flaw: the issuance of a single show-cause notice that improperly combined multiple financial years, a practice the court deemed “impermissible in law.” This judgment reaffirms a critical procedural requirement for tax authorities under the Goods and Services Tax (GST) Act.
The petitioner challenged a notice from June 2025 and a subsequent one later that month, both of which covered the period from April 2018 to March 2024. The assessee’s counsel argued that such a “bunching” of show-cause notices for different financial years was without jurisdiction. The court considered this issue in light of its own prior common order dated July 21, 2025, from a batch of similar cases (W.P.Nos.29716 of 2024, etc., batch), which provides a clear framework for the issuance of such notices.
Following its precedent, the Madras High Court held that the GST Act only permits the issuance of show-cause notices based on a single “tax period.” The court specified that if an annual return is filed, the entire financial year constitutes the relevant tax period. Consequently, a single notice must be confined to a single financial year and cannot be clubbed with others. The court found that the impugned notices were issued without jurisdiction because they improperly combined multiple financial years.
