Issuance of a single show cause notice or assessment order for multiple financial years under the GST Act is prohibited

Last updated: 01 November 2025
Quick Summary
The Madras High Court has ruled that GST authorities are prohibited from issuing a single show cause notice or assessment order that covers multiple financial years. The court found that such consolidated notices violate statutory requirements, prejudice taxpayers by limiting their ability to gather evidence and contest issues year by year, and disregard the specific limitation periods applicable to each financial year. Consequently, any notices or orders combining multiple years have been quashed.

Court :
Madras High Court

Brief :
The Hon'ble Madras High Court in the case of Smt. R. Ashaarajaa v. Senior Intelligence Officer [W.P.Nos.29716, 29720, 29726 & 34137 of 2024, order dated July 21, 2025] held that clubbing several financial years in a single show cause notice or assessment order under the GST Act is impermissible, as it violates statutory requirements for separate notices per tax period, prejudices taxpayer rights, and runs counter to limitation periods fixed for each year. ​

Citation :
W.P.Nos.29716, 29720, 29726 & 34137 of 2024, order dated July 21, 2025

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1 Year PLAN
1999
(Excl. of GST ₹359)

BEST VALUE
2 Years PLAN
3499
(Excl. of GST ₹629)

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Bimal Jain
Published in GST
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