TMI Blog2024 (10) TMI 116X X X X Extracts X X X X X X X X Extracts X X X X ..... R In this writ petition, the petitioner, a Club, challenges the impugned show cause notice dated 07.05.2024, as detailed in Annexure-F, and the summary of the show cause notice dated 08.05.2024, as outlined in Annexure-G, issued by the respondent for the tax periods 2019-20, 2020-21, 2021-22, 2022-23, and 2023-24. The petitioner contends that these notices, issued under Section 73 of the Central ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n the case of M/s. Titan Company Ltd. vs. Joint Commissioner of GST [W.P.No.33164 of 2023]. The Madras High Court, while addressing a similar issue, relied on the Hon'ble Supreme Court's decision in State of Jammu and Kashmir and Others vs. Caltex (India) Ltd., [AIR 1966 SC 1350]. The Hon'ble Apex Court held that where an assessment encompasses different assessment years, each assessment order ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... judgment cited by the Hon'ble Supreme Court are directly applicable to the present case. 6. For the reasons aforementioned, this Court concludes that the show cause notices issued by the respondent are fundamentally flawed. The practice of issuing a single, consolidated show cause notice for multiple assessment years contravenes the provisions of the CGST Act and established legal precedents. 7. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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