Whether issuance of a consolidated SCN u/Sec. 73/74 bunching multiple years valid matter referred to Larger Bench { Rollmet LLP vs. Union of India [2026] 185 taxmann.com 599 (Bombay)}
Facts :
Petitioner was issued a single consolidated Show Cause Notice by the department under Sections 73/74 of the GST Act, covering multiple financial years in one notice. The petitioner challenged the notice before the High Court on the ground that such clubbing of different assessment years is improper and contrary to law.
Issue:
Whether the department is legally permitted to issue one consolidated SCN for multiple financial years under Sections 73/74, instead of issuing separate SCNs for each financial year/tax period.
Held:
The Bombay High Court referred the issue to a Larger Bench for authoritative determination without giving a final ruling on merits.
