Divergent Rulings on Consolidation of Multiple Financial Years in Single SCN

Last updated: 09 May 2026

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Quick Summary

The Delhi High Court has ruled that it is permissible to combine multiple financial years into a single Show Cause Notice (SCN) and adjudication order under Sections 73 and 74 of the CGST Act. This applies even when the case does not involve fraud, such as disputes over tax classification or rates. The court found that the wording of the Act allows for notices covering 'any period' or 'such periods', supporting the consolidation of different financial years. Consequently, the petitioner's challenge to an SCN covering several years was dismissed, with the court directing them to pursue the available appellate remedy.

Court :
Delhi High Court

Brief :
The Hon’ble Delhi High Court in the case of M/s. Technosys Integrated Solutions Pvt Ltd v. Union of India & Ors. [W.P.(C) 5581/2025, order dated March 16, 2026] held that consolidation of multiple financial years in a single Show Cause Notice (SCN) and adjudication order is permissible under Sections 73 and 74 of the CGST Act, even in cases not involving fraudulent Input Tax Credit, and declined interference in writ jurisdiction in view of the availability of an alternate appellate remedy.

Citation :
W.P.(C) 5581/2025, order dated March 16, 2026

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1 Year PLAN

1999

(Excl. of GST ₹359)

2 Years PLAN

3499

(Excl. of GST ₹629)

BEST VALUE

3 Years PLAN

4999

(Excl. of GST ₹899)

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Attached File : 671907_5979_technosys_integrated_solutions_pvt_ltd.pdf

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Judgement posted by

Bimal Jain

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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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