Revenue cannot consolidate multiple financial years in a single Show Cause Notice; such clubbing is without jurisdiction and constitutes a judicial overreach

Last updated: 18 November 2025

Quick Summary

The Bombay High Court has ruled that tax authorities cannot combine multiple financial years into a single Show Cause Notice for GST demands. The court found this practice to be beyond the jurisdiction of the Revenue and an overreach of judicial power. Such consolidated notices infringe upon an assessee's rights to contest demands for specific periods and are therefore invalid.

Court :
Bombay High Court

Brief :
The Hon'ble Bombay High Court in the case of Milroc Good Earth Developers v. Union of India & Ors. [Writ Petition No.2203 of 2025, order dated October 09, 2025] held that the Revenue's act of consolidating various financial years into a single Show Cause Notice for GST demand and recovery of ineligible Input Tax Credit is without jurisdiction, amounting to judicial overreach, and therefore such demand notices are liable to be quashed.

Citation :
Writ Petition No.2203 of 2025, order dated October 09, 2025

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