Bombay High Court: M/s. Rollmet LLP, and Ors. v. The UOI and Ors. [2026 (4) TMI 1218]
[Validity of SCN issued for Multiple SCN referred to Larger Bench]
Consolidated show cause notices issued under Sections 73 and 74 of the CGST Act were challenged on the ground
that multiple financial years cannot be clubbed together. The department argued that the Act does not prohibit
issuance of a composite notice so long as limitation for each year is independently complied with. The Court
observed that conflicting views existed among various High Courts and prima facie held that Sections 73 and 74 do
not bar issuance of a consolidated show cause notice for multiple years. The Court further observed that limitation
under Sections 73(10) and 74(10) applies to passing of the final order and not to issuance of a common notice.
Considering the important legal issues involved, the matter was referred for reconsideration by a Larger Bench.
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