GST | Allahabad High Court Grants Stay On Composite Show Cause Notice For Multiple Assessment Years

Recently, the Allahabad High Court has granted stay on composite show cause notice issued by the Directorate General of GST Intelligence where multiple assessment years have been clubbed in one show cause notice. Petitioner approached the High Court against a single show cause notice issued by the Additional Director, Directorate General of GST Intelligence, Ghaziabad for tax period starting from August 2019 to September 2023. It was pleaded that the same could not be done as each tax period is a separate cause of action. Petitioner relied on an earlier interim order of the Allahabad High Court where under similar circumstances, stay had been granted. Further reliance was placed on decisions of the Karantaka High Court in Vermax Technologies Serviced Ltd. Vs. Assistant Commissioner of Central Tax, Bangalore and Goa Bench of the Bombay High Court in Milroc Good Earth Developers Vs. Union of India where the Courts have ruled in favour of the assesee and have held that composite show cause notice clubbing various assessment years to be barred by law. The bench of Justice Saumitra Dayal Singh and Justice Vivek Saran observed that “Clearly, matter requires consideration. It is also noted that the coordinate bench has earlier granted reasoned interim order. No contrary order has been passed by any other bench. Keeping in mind the rule of consistency that may ensure transparency in court proceedings and further keeping in mind the fact that three other High Courts have dealt with the issue and answered the same in favour of the assessee, at present case for interim protection has been made out in this case and the cases listed at serial no. 244 of the cause list (wherein no interim protection has been granted till date.” Accordingly, interim protection was extended to the petitioner. The matter is listed on 6th January, 2026 for final hearing. Mr. Dhruv Agrawal, Senior Advocate assisted by Ms. Upasna Agrawal, Mr. Varun Srivastava, Mr. Nalin Talwar, Mr. Rajesh Thakur and Mr. Salil Arora appeared for the petitioner. Case Title: M/S S.D. Freshners Ltd. Through Its Director Shri Mahesh Prasad And Another Versus Union Of India And 5 Others [WRIT TAX No. - 7500 of 2025] Click Here To Read/Download Order

GST | Allahabad High Court Grants Stay On Composite Show Cause Notice For Multiple Assessment Years

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