Quest Infotech Private Limited & Anr Vs Union of India & Ors. (Delhi High Court)
Delhi High Court is currently deliberating on the legality of consolidated Show Cause Notices (SCNs) and subsequent orders issued by Goods and Services Tax (GST) authorities that span multiple financial years. The court heard arguments in a petition filed by Quest Infotech Private Limited, challenging an order dated February 2, 2025, primarily on the ground that a single SCN covered the period from 2017 to 2022.
Quest Infotech Private Limited contends that under Section 74(10) of the Central Goods and Services Tax (CGST) Act, 2017, the Department is obligated to issue separate SCNs and pass distinct orders for each financial year. Their counsel argued that such consolidation is impermissible when read with Section 74(2) and (3) of the Act and Rule 142 of the CGST Rules.
To support this position, the petitioner cited two judicial precedents:
1. The Kerala High Court’s Division Bench judgment in Joint Commissioner (Intelligence & Enforcement) vs. Lakshmi Mobile Accessories (2025 SCC OnLine Ker 852).
2. The Karnataka High Court’s Single Judge judgment in Veremax Technologie Services Pvt. Ltd. vs. The Assistant Commissioner Of Central Tax (Writ Petition No.15810 of 2024 (T-Res)).
The petitioner’s counsel further submitted that an SCN under Section 74 can potentially be converted into one under Section 73 of the Act, reinforcing the argument against consolidation of notices or final orders for multiple periods.
