Delhi High Court Allows Consolidated Appeal Against Single GST Demand Order Covering Multiple Financial Years

The Delhi High Court has allowed the filing of a consolidated appeal in a matter where a 'common and single' order was issued, although the demand pertained to multiple financial years. In an order dated November 18, 2025, the Division Bench comprising Justice Prathiba M. Singh and Justice Shail Jain allowed the Petitioner to take recourse to a single consolidated appeal against consolidated GST demands raised via one order while stating that whether Section 74 was correctly invoked was a matter for appeal. A total demand of Rs. 40,82,014 which included tax, interest, penalty was issued covering multiple financial years but was consolidated in one order. The demand was premised on multiple audit findings like Short payment of tax due to reconciliation of GSTR-3B,GSTR-9, balance sheet, excess availment of Input Tax Credit as shown in GSTR-2A and GSTR3B in Financial Year 2019-20 & 2020-21, late filing of GSTR-3B, reversal of Input Tax Credit in respect of blocked credit as per Section17(5)of the CGST Act, 2017. In respect of consolidated demands, the Petitioner asserted that separate DRC‑07 forms should have been issued for each financial year. On the contrary, the GST Department refuted and claimed that audit paragraphs clearly recorded year‑wise demands, DRC‑07 consolidated them into one order. In this vein, the High Court from common demand order noted that “amounts are clearly decipherable” and extended the time for pre-deposit till December 20, 2025 while permitted the Petitioner to file 'one consolidated appeal' qua demand order. As for the invocation of Section 73 or Section 74 of the CGST Act, the Petitioner contended that Section 74 CGST Act could not be invoked since Show Cause Notice was based only on data like GSTR-3B,GSTR-9 and the balance sheet already available on the GST portal. The GST Department submitted that the same could be raised in appeal. Accordingly, the High Court disposed of the writ petition. Case Detail: South East Asia Company vs. Superintendent, CGSTCitation: 2025 LiveLaw (Del) 1633 Case No.: W.P.(C) 17469/2025 For Appellant: Advocates Sparsh Bhargava, Ishita Farsaiya, Riddhi Vasistha, Vanshika Taneja For Respondent: SSC Monica Benjamin with Advocate Nancy Jain Click here to read the order.

Delhi High Court Allows Consolidated Appeal Against Single GST Demand Order Covering Multiple Financial Years

Parul Bose

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