GST Show Cause Notices Can Cover Multiple Financial Years: No Statutory Bar Under Sections 73/74 of the GST Act: Karnataka HC

Last updated: 04 May 2026

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Quick Summary

The Karnataka High Court has ruled that Goods and Services Tax (GST) show cause notices issued under Sections 73 and 74 of the CGST Act are not restricted to a single financial year. The court held that a single notice can cover multiple financial years, overturning previous decisions by a single judge. This decision aligns with rulings from the Delhi, Allahabad, and Jammu & Kashmir High Courts, aiming to reduce administrative burdens.

Court :
Karnataka High Court

Brief :
The Hon'ble Karnataka High Court (Division Bench) in The Commissioner of Central Tax v. Chimney Hills Education Society [Writ Appeal No. 1751 of 2024 (T-RES) and connected matters dated April 23, 2026] allowed the intra-court appeals filed by the Revenue, setting aside the orders of the learned Single Judge which had quashed common/consolidated show cause notices (SCNs) issued under Sections 73 and 74 of the Central Goods and Services Tax Act, 2017 ( 'the CGST Act' ) covering multiple financial years. The Court held that show cause notices issued under Sections 73/74 of the CGST Act are neither tax period-specific nor financial year-specific, and that there is no statutory bar to the issuance of a common SCN covering multiple tax periods or financial years.

Citation :
Writ Appeal No. 1751 of 2024 (T-RES) and connected matters dated April 23, 2026]

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