Bombay High Court Refers Issue of Single GST Notice for Multiple Years to Larger Bench

A three-judge bench of the Bombay High Court will now decide if the GST Department can issue a single consolidated show-cause notice (SCN) covering multiple financial years.

The Division Bench referred the issue following conflicting High Court rulings. Petitioners argue that the CGST Act follows a "year-wise" assessment scheme and clubbing years violates statutory limitation periods.

Conversely, the Revenue points to decisions from Delhi and Allahabad upholding consolidated notices, particularly in fraud cases.

The Court noted that prohibiting such notices might "re-write" the statute, but referred the matter to ensure legal certainty across sectors like banking and manufacturing.

[Rollmet LLP v. UOI]