‘Bunching’ of GST notices across Multiple FYs Not Permissible: Madras HC; Holds Section 74A applicable from FY 2024-25 [Read Order]

The Madras High Court held that GST ( Goods and Services Tax 0 authorities cannot issue a single show cause notice or pass a common assessment order by clubbing multiple financial years together.

Justice Krishnan Ramasamy also clarified that after the omission of Sections 73 and 74 w.e.f. 01.04.2024, the department can proceed only under Section 74A for FY 2024-25 onwards, and therefore issuance of notices under Section 73 for later years reflects non-application of mind.

Shot X Retail Private Limited challenged an assessment order dated 15.12.2025, passed under Section 73 of the TNGST Act, 2017, where the respondent issued a single consolidated proceeding for four financial years FY 2022-23 to FY 2025-26 under the same GSTIN.

The petitioner also raised the issue that Section 73 does not apply to FYs 2024-25 and 2025-26. It submitted that the issuance of a combined show cause notice and a consolidated order covering multiple years was contrary to law.

It had already been settled by the High Court earlier, which held that a show cause notice must be issued based on the relevant tax period and cannot be clubbed for more than one financial year, asserted the petitioner.

The State accepted the petitioner’s submissions before the Court without defending the orders.

The High Court found that the impugned order was clearly passed for more than one financial year, which is legally not allowed. Therefore the same was quashed by the court.

Further, the bench also held that the department’s notice under Section 73 for FY 2024-25 and FY 2025-26 was without jurisdiction due to the statutory omission of Sections 73 and 74 from 01.04.2024.

Therefore, according to the court, the order completely suffered from total non-application of mind.

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