Consolidated GST Notices Valid as Law Does Not Restrict to Financial Year: Karnataka HC

Commissioner of Central Tax Vs Chimney Hills Education Society (Karnataka High Court)

GST Show Cause Notices Can Cover Multiple Financial Years — No Statutory Bar Under Sections 73/74 of the GST Act: Karnataka HC

The Hon’ble Karnataka High Court (Division Bench) in The Commissioner of Central Tax v. Chimney Hills Education Society [Writ Appeal No. 1751 of 2024 (T-RES) and connected matters dated April 23, 2026] allowed the intra-court appeals filed by the Revenue, setting aside the orders of the learned Single Judge which had quashed common/consolidated show cause notices (SCNs) issued under Sections 73 and 74 of the Central Goods and Services Tax Act, 2017 (‘the CGST Act’) covering multiple financial years. The Court held that show cause notices issued under Sections 73/74 of the CGST Act are neither tax period-specific nor financial year-specific, and that there is no statutory bar to the issuance of a common SCN covering multiple tax periods or financial years.

Facts:

The appellants/Revenue issued a show cause notice under Section 74 of the CGST Act for the period from July 2017 to March 2023, alleging defaults on account of fraud, wilful misstatement, or suppression of facts. The material forming the foundational basis for issuance of the SCN was enclosed along with the notice.