Santosh Supplies Vs Union of India (Madras High Court)
The Madras High Court, in a batch of writ petitions, examined the validity of orders dated 30.12.2025 passed by the fourth respondent, where show cause notices and consequential orders had been issued by clubbing together multiple financial years, namely 2018-19 to 2021-22. The petitioners challenged the impugned orders primarily on the ground that the issuance of a single show cause notice and a consolidated adjudication order covering several financial years was impermissible under the GST framework.
The petitioners contended that the issue had already been settled by the Madras High Court in R.A. and Co. v. Additional Commissioner of Central Taxes, Chennai South, reported in (2025) 33 Centax 14 (Mad.), wherein the Court had held that bunching of show cause notices for multiple financial years was contrary to the provisions of the GST Act. On that basis, they sought quashing of the impugned orders.
The respondents relied upon a circular issued by the Government of India, Ministry of Finance, Department of Revenue, Central Board of Indirect Taxes and Customs dated 15.09.2025. According to them, the circular, after considering various judicial pronouncements, concluded that a single show cause notice could be issued for multiple assessment years. They submitted that the impugned orders had been passed on the strength of the said circular and therefore warranted no interference.
