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Karnataka HC Upholds Validity of Common GST Show Cause Notices for Multiple Tax Periods

Case Law Details

TaxGuru Citation
2026 taxguru.in 10071
Case Name
Assistant Commissioner of Central Tax Vs Ozone Facility Management Pvt. Ltd. (Karnataka High Court)
Date of Judgement/Order
Only available for paid members
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Assistant Commissioner of Central Tax Vs Ozone Facility Management Pvt. Ltd. (Karnataka High Court)

The Karnataka High Court allowed a writ appeal challenging the order of the Single Judge, who had quashed a common show cause notice issued under Section 74 of the CGST/KGST Act, 2017 for the tax periods 2019-20 to 2023-24 while granting liberty to initiate fresh proceedings in accordance with law.

The respondent had filed a writ petition challenging the common show cause notice dated 03.09.2025 and 10.09.2025. The Single Judge allowed the petition and quashed the notice.

The Division Bench noted that, in W.A. No.1751/2024 and connected matters, decided on 24.04.2026, the High Court had already held that consolidated or common show cause notices are permissible. The earlier judgment also directed that where matters were at the stage of submitting replies to the show cause notice, they should be remitted to the Adjudicating Authority for consideration of objections and passing of appropriate orders.

Following the earlier judgment, the High Court allowed the writ appeal, set aside the Single Judge’s order dated 17.12.2025, and remitted the matter to the Adjudicating Authority to receive the respondent’s objections and proceed in accordance with law. The respondent was granted four weeks from the date of uploading of the order to file objections to the common show cause notices.

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Author Info

CA Sandeep Kanoi
Qualification: CA in Job / Business
Company: Taxguru Consultancy
Location: Mumbai, Maharashtra
Articles Published: 20,146

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