One GST SCN for Multiple Financial Years Permissible — SC to Settle this GST Battle. Read the key points, why it matters and what businesses should watch next.
High Courts Draw A Line
Several High Courts have taken a consistent position against the GST department's practice of clubbing several financial years or tax periods into one show-cause notice and one adjudication order under Sections 73 and 74 of the CGST Act, 2017. The Andhra Pradesh High Court has quashed such composite proceedings in Sahiti Agencies, M/s. Supraja Dairy Private Limited and Sri Ganesh Steels and Cements. In Sahiti Agencies, an order-in-original and Form GST DRC-07 summaries covering July 2017 to March 2023 were set aside. In Supraja Dairy, a composite notice and order spanning July 2017 to 2020-21 were quashed, with liberty granted to start fresh proceedings. In Sri Ganesh Steels, both the assessment order for July 2017 to 2021-22 and the appellate order were set aside. The Bombay High Court (Nagpur Bench), in M/s. Techops Infrastructure Pvt. Ltd., reached a similar conclusion against the DGGI.
The Supreme Court Steps In
The Revenue has challenged these rulings before the Supreme Court. Notice was issued in the Sahiti Agencies matter, in the Supraja Dairy matter and in the Sri Ganesh Steels matter. All related matters have been tagged with the lead SLP (C) No. 6232/2026 and listed before a bench of Justice J.B. Pardiwala and Justice K.V. Viswanathan. During the hearing, the Union of India stated that the Government is considering amendments to address the issue, with internal discussions already underway.
Why It Matters For Businesses
The issue goes to the heart of GST adjudication procedure. If a single notice or order cannot lawfully cover more than one tax period, composite demands become vulnerable to challenge, and taxpayers gain a procedural ground to seek fresh, year-wise adjudication. Until the Supreme Court settles the question, the position remains unsettled, and the outcome will affect how pending and future notices are framed and defended.
What To Watch Next
The key developments to track are the Supreme Court's final pronounceme…
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