The Bombay High Court ruled that GST show cause notices under Section 74 cannot consolidate assessments from multiple financial years, emphasizing the independent nature of each year's tax assessments.
Bombay HC: Independent Assessment for Each Financial Year Required
The Bombay High Court has held that show cause notices under Section 74 of the CGST Act cannot combine multiple financial years into a single proceeding. The Court ruled that assessments and limitation periods for GST operate separately for each financial year, reinforcing the integrity of distinct annual assessments.
This decision affirms the principle that taxpayers should not face compounded liabilities across years without adequate notice and opportunity to contest each year's tax obligations individually. The ruling protects taxpayer rights under the GST regime and ensures fair administrative processes.
Legal practitioners should consider the ramifications of this judgment, as it provides clarity on the treatment of multi-year assessments and could influence compliance and litigation strategies regarding GST matters.
Citations
- Bombay HC (2026)
