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Calcutta HC Stays GST Hearing on Clubbed Multi-Year Section 74 SCN

Case Law Details

TaxGuru Citation
2025 taxguru.in 10665
Case Name
IVL Dhunseri Petrochem Industries Private Vs Additional Commissioner of CGST and Central Excise Haldia Comm. And Anr. (Calcutta High Court)
Date of Judgement/Order
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IVL Dhunseri Petrochem Industries Private Vs Additional Commissioner of CGST and Central Excise Haldia Comm. And Anr. (Calcutta High Court)

Sub: Whether one single SCN for multiple years can be issued under the GST Law?

An interesting question interalia arose before Hon’ble Calcutta High Court in this case where combined show cause notice for financial years 2018-19 to 2021-22 was issued and the petitioner relied on several decisions of High courts across the country to argue that the same was not permissible.

In support of his contention, he relied on the following judgments M/s. Milroc Good Earth Developers, Mariposa Beach Grove v. Union of India reported in 2025(10) TMI 867- Bombay High Court, S. J. Constructions, Suma Infra, M/s. SKS Traders, Bhaarat Scrap Traders v. The Assistant Commissioner and Others reported in 2025 (9) TMI 1215- Andhra Pradesh High Court, Pepsico India Holdings Pvt. Ltd. v. Union of India reported in (2025) 35 Centax 86 (Gau) and Goverdhandham Estate Pvt. Ltd. V. State of Rajasthan reported in (2025) 25 Centax 400 (Raj.).

The Respondent department argued that clubbing of SCNs is permissible under the law.

He relies on Ambika Traders Through Proprietor Gaurav Gupta versus Additional Commissioner, Adjudication DGGSTI, CGST, Delhi North reported in 2025 SCCOnLine Del6913 to support his argument. The respondent requested for time to go through the judgements which were cited by the petitioner in its contention.

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Author Info

CA Jatin Minocha
Qualification: CA in Practice
Location: Delhi, Delhi
Articles Published: 637

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