Kerala High Court Quashes Consolidated GST Show Cause Notice Covering Multiple Financial Years: Sri Sri Granites Vs Assistant Commissioner
Background and Overview
A significant ruling has emerged from the Kerala High Court concerning the legal validity of consolidated Show Cause Notices issued under GST law. In Sri Sri Granites Vs Assistant Commissioner, the Court addressed a writ petition filed by the assessee challenging a single omnibus Show Cause Notice that clubbed together multiple financial years — specifically covering the period from 2019-2020 through 2023-2024 — into one composite document. The Court, relying on binding precedents established by its own Division Bench, firmly held that such a practice is legally untenable and accordingly quashed the impugned notice.
This judgment carries considerable practical significance for assessees who may be facing similarly structured notices from GST authorities, as it reinforces the principle that each assessment year must be treated as a distinct and independent proceeding.
The Core Issue: What Was Challenged?
The assessee approached the Kerala High Court by way of a writ petition, directing its challenge specifically at Ext.P1 — a consolidated Show Cause Notice issued by the respondent authorities. The objectionable feature of this notice was that it purported to cover five consecutive financial years — 2019-2020, 2020-2021, 2021-2022, 2022-2023, and 2023-2024 — within a single document, rather than issuing separate notices for each year.
The fundamental legal objection raised by the assessee was straightforward: a composite Show Cause Notice bundling multiple assessment years together into one proceeding is not legally sustainable under GST law.
The respondent authorities, represented by the Standing Counsel, were heard on the matter. The Court, upon careful consideration of the rival submissions, found force in the assessee's argument.
Precedents Relied Upon
The legal foundation for the assessee's challenge rested on two significant decisions of the Kerala High Court itself:
1. Joint Commissioner (Intelligence & Enforcement) v. M/s. Lakshmi Mobiles Accessories [2025 KHC OnLine 149]
This decision, rendered by a Division Bench of the Kerala High Court, had already categorically held that issuance of a composite notice covering multiple assessment years is not legally sustainable. The Division Bench examined the structural framework of GST proceedings and concluded that each financial year constitutes an independent unit of assessment, thereby necessitating separate notices for each such period.