Consolidated GST Show Cause Notice for Multiple Years: Bombay HC Refers Matter to Larger Bench


Quick Summary
The Bombay High Court has referred a significant legal question regarding the validity of consolidated Goods and Services Tax (GST) show cause notices covering multiple financial years to a Larger Bench. The court noted a split in judicial opinion among various High Courts and the Supreme Court's stance on similar matters. This referral aims to provide a definitive ruling on whether such consolidated notices are legally permissible under the CGST Act.

Court :
Bombay High Court

Brief :
The Hon'ble Bombay High Court in M/s Rollmet LLP & Ors v. Union of India & Ors [WP No. 16848 of 2025 & connected matters dated April 17, 2026] examined a batch of writ petitions challenging the legality of single consolidated show-cause notices issued under Sections 73/74 of the Central Goods and Services Tax Act, 2017 ("the CGST Act" ) covering multiple financial years. The Division Bench, noting a significant divergence of judicial opinion across High Courts — and the Supreme Court's dismissal of a Special Leave Petition in Mathur Polymers v. Union of India — declined to follow the co-ordinate Bench decision in Milroc Good Earth Developers v. Union of India and instead referred five substantial questions of law to a Larger Bench for authoritative determination.

Citation :
WP No. 16848 of 2025 & connected matters dated April 17, 2026

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FCA, FCS LLB with21 Yrs of Experience inTaxation Indirect and Direct: Education Qualification: B.Com (Hons) Chartered Accountants Company Secretary LLB Qualified SAP FI/CO Consultants Professional Membership: Chairmanof Indirect Tax Committee of PHD Chamber of Commerce Member of Indirec ... Read more

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