CGST law permits consolidated show-cause notices and adjudication orders across multiple financial years.

M/S Abala Auto Agency, a proprietorship firm, challenged the Order-in-Original dated 10 October 2025, by which tax of ₹1,58,64,297, along with applicable interest and penalty, was adjudged for the financial years 2017–18 to 2019–20.

The principal jurisdictional challenge was that the authorities had issued a consolidated Show Cause Notice and passed a consolidated adjudication order covering multiple financial years.

The petitioner also raised other issues on the merits of the impugned order, but the Court confined its consideration to the jurisdictional objection.

Whether the Proper Officer could issue a consolidated Show Cause Notice under the Central Goods and Services Tax Act, 2017 for multiple financial years, namely 2017–18 to 2019–20?

Whether the Proper Officer could pass a consolidated Order-in-Original covering multiple financial years under the CGST Act, 2017?

Whether the petitioner should be relegated to the statutory appellate remedy under Section 107 of the CGST Act, with protection concerning limitation and interim relief?

The Court applied Sections 73(1) and 74(1) of the Central Goods and Services Tax Act, 2017, concerning the issuance of Show Cause Notices for tax not paid, short-paid, or erroneously refunded, and Sections 73(9) and 74(9), concerning adjudication and determination of tax, interest, and penalty.

Relying on M/S Tata Projects Limited v. Union of India & Others, 2026 SCC OnLine Gau 3798, the Court held that the CGST Act does not bar the issuance of a consolidated Show Cause Notice or the passing of a consolidated adjudication order for different financial years.

The Court also applied Section 107 of the CGST Act, which provides the statutory appellate remedy against an adjudication order.

The Court treated the permissibility of consolidated proceedings as the determinative jurisdictional issue.

It followed the binding reasoning already laid down in M/S Tata Projects Limited, under which Sections 73 and 74 do not prohibit a single Show Cause Notice or adjudication order covering multiple financial years.

Applying that rule, the Court held that the Proper Officer acted within the statutory jurisdiction in issuing a consolidated notice and passing the Order-in-Original dated 10 October 2025 for 2017–18 to 2019–20.

Since no jurisdictional error was established, the Court declined to entertain the writ petition on that ground.

However, it expressly refrained from examining the merits, legality, or validity of the tax demand and preserved those objections for determination in the statutory appeal.

The Court held that the Proper Officer had jurisdiction to issue a consolidated Show Cause Notice and pass a consolidated order for the financial years 2017–18 to 2019–20.

All issues concerning the merits of the order were left open.

The petitioner was granted liberty to file an appeal under Section 107 of the CGST Act within 30 days from the judgment, and the Appellate Authority was directed to decide the appeal without insisting on limitation.

Existing interim protection was directed to continue until consideration of the stay application by the Appellate Authority, subject to filing the appeal within the stipulated period.

The Appellate Authority remained free to pass appropriate orders on the stay application, and no costs were awarded.