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GST litigation is currently divided over whether authorities can issue single, consolidated Show Cause Notices (SCNs) for multiple financial years. High Courts in Madras, Kerala, and Bombay have quashed such notices, arguing the CGST Act treats each financial year as a separate unit with independent limitation periods. Conversely, the Delhi and Allahabad High Courts permit "bunching," interpreting the phrase "any period" in Sections 73 and 74 as allowing flexible, issue-based adjudication. Due to these conflicting rulings and practical portal challenges, the Bombay High Court has referred the dispute to a Larger Bench.
INTRODUCTION
The question of whether the revenue authorities can issue a single, consolidated Show Cause Notice (SCN) covering multiple financial years or tax periods has emerged as a significant point of contention in Goods and Services Tax (GST) litigation. This issue has created a sharp "difference of opinion" among various High Courts across India. Recently, the Bombay High Court, in the case of M/s. Rollmet LLP vs. The Union of India1, took note of these conflicting precedents—specifically the discrepancy between its own earlier decision in Milroc Good Earth Developers2 and the views of the Delhi an
