ICAD School of Learning Pvt. Ltd. Vs Union of India (Bombay High Court)
In this case Bombay High held that, single SCN covering multiple years, you would be aggregating different tax period with different due dates and different limitations, which the statute does not permit. And hence consolidation of show cause notice for multiple years is not permissible.
The Bombay High Court, in Writ Petition No. 736 of 2026, examined the validity of a show cause notice dated 01/05/2025 issued under Section 74 of the Central Goods and Services Tax Act, 2017 (CGST Act), and the consequential order dated 30/12/2025. The notice covered the period from April 2018 to March 2023 and alleged that the petitioner had rendered a composite supply of taxable commercial training services along with hostel facilities, resulting in short payment of tax and wrongful availment of input tax credit.
The principal issue was whether a single show cause notice under Section 74 could validly consolidate multiple financial years or tax periods. The petitioner relied on earlier Division Bench judgments of the Bombay High Court in Milroc Good Earth Developers (Goa Bench) and Rite Water Solutions (India) Ltd., where it was held that consolidation of different financial years or tax periods in one notice is not permissible under the CGST Act.
