Legality of Consolidated GST Show Cause Notices Affirmed by Karnataka High Court for Successive Tax Periods

The issuance of a single, consolidated show cause notice spanning multiple financial years has been a subject of extensive litigation under the Goods and Services Tax (GST) regime. Addressing this procedural contention, the Karnataka High Court in the landmark matter of Assistant Commissioner of Central Tax Vs Ozone Facility Management Pvt. Ltd. has definitively upheld the legal validity of issuing a common show cause notice for multiple tax periods.

This judicial summary explores the factual matrix, the legal arguments, and the ultimate ruling delivered in Writ Appeal No. 1302 of 2026 (T-RES), dated 16/07/2026, which provides crucial clarity for both the revenue department and the assessee.

Factual Background of the Dispute

The genesis of the litigation lies in the issuance of common show cause notices dated 03.09.2025 and 10.09.2025 to the assessee. These notices were issued by the GST department invoking Section 74 of the CGST/KGST Act, 2017.