GST SCN Quashed as Clubbing Multiple Financial Years Violates Section 74 Scheme

Hakikatrai and Sons Vs Union of India and Ors. (Bombay High Court) The Bombay High Court quashed a show cause notice dated 26/06/2025 issued under Section 74 of the CGST Act for financial years 2018-19 to 2022-23, holding that consolidation of multiple financial years in a single notice is impermissible. The petitioner challenged the notice on the ground that the statutory scheme of the CGST Act contemplates assessment and limitation on a year-wise basis. Relying on its earlier decisions in Milroc Good Earth Developers and Rite Water Solutions, the Court reiterated that tax liability, limitati...