Judicial Corner: Whether there can be one order under GST for multiple years i.e. one DRC-07 for 4 years (FY 2017-18 to FY 2020-21) (07.07.2025)

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Whether there can be one order under GST for multiple years i.e. one DRC-07 for 4 years (FY 2017-18 to FY 2020-21){ India News Media (P.) Ltd. vs. Assistant Commissioner Okhla Division CGST Delhi [2025] 174 taxmann.com 1269 (Delhi)}

 Facts :

 The petitioner received a single show cause notice and a consolidated demand order (DRC‑07) under Section 74 of the CGST Act.

  • This notice covered multiple financial years from FY 2017‑18 to FY 2020‑21.
  • No separate hearings were conducted for each financial year.

Issues:

  • Can the GST department issue a single SCN and DRC‑07 for multiple financial years under Section 74?
  • Does failing to conduct separate hearings per year violate natural justice?

 

Held:

  • A consolidated demand order covering different financial years is not valid.
  • The department must issue separate SCNs and DRC‑07 for each financial year.
  • Each year should be treated independently under GST proceedings.