Single GST SCN Covering Five Financial Years is Impermissible: Madras HC Quashes Order [Read Order]

In a recent ruling, the Madras High Court quashed a consolidated GST assessment order covering five financial years 2019-20 to 2023-24, holding that clubbing of tax periods in a single show cause notice is impermissible under law.

The writ petition was filed by the petitioner, Dream Infotech, represented by its proprietor, challenging the impugned order dated 29.10.2025, passed by the state tax officer, which had issued a single show cause notice and assessment order for the tax periods 2019–20 to 2023–24.

The petitioner argued that the proceedings were without jurisdiction and violated principles of natural justice, as the GST Act mandates issuance of notices based on individual tax periods.

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The petitioner also included that on a prior common order of the High Court dated 21 July 2025 in W.P. No. 29716 of 2024 batch, where it was categorically held that show cause notices cannot be clubbed across multiple financial years.

wherein it has been held as follows:

“28. (i) The GST Act permits only for issuance of show cause notice based on the tax period. Therefore, if the annual return is filed, the entire year would be considered as a tax period and accordingly, the show cause notice shall be issued based on the said annual returns.

(ii) If show cause notice is issued before the filing of annual returns, the same can be issued based on the filing of monthly returns;

(iii) If show cause notice is issued after the filing of annual returns or after the commencement of limitation, the said notice shall be issued based on the annual returns with regard to the relevant financial year.

(iv) No show cause notice can be clubbed and issued for more than one financial year since the same is impermissible in law.

(v) In these cases, without any jurisdiction, the impugned show cause notices/orders came to be issued/passed for more than one financial year, which is impermissible in law and hence, the same is liable to be quashed. Accordingly, the impugned show cause notices/orders stand quashed based on the aspect of clubbing of show cause notices for more than one financial year.”

The respondent argued that all the submissions made infront of court is fair and requests the Court to pass appropriate orders

After hearing both sides the high court observed that the impugned order was indeed passed by for more than one financial year by the respondent without any jurisdiction, which is impermissible in law .

The bench, Justice Krishnan Ramasamy quashed the assessment order dated 29.10.2025 along with all the other consequential orders and also set aside the show cause notice dated 02.07.2025. Liberty was granted to the tax department to initiate fresh proceedings separately for each financial year.

Accordingly the writ petition was disposed of with no cost and consequently, the connected miscellaneous petition is also closed.

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