Disputed questions on GST notice clubbing and limitation should be resolved through statutory adjudication.

Respondent No. 3 issued a show-cause-cum-demand notice dated 18 August 2026, demanding ₹55,29,508 under the Central Goods and Services Tax Act, 2017, by clubbing financial years 2021–22 to 2025–26.

The petitioner challenged the notice, contending that clubbing multiple financial years in one notice was impermissible and that the demand was barred by limitation under Section 74; the petitioner also stated that proceedings concerning two periods were pending before the appellate authority.

The respondents objected to writ maintainability on the ground that an appeal under Section 107 was available and relied, among other authorities, on *Mathur Polymers* and *UBS Exports International*.

Whether the writ petition should be entertained where the petitioner could raise the issues of clubbing and limitation in an appeal under Section 107 of the CGST Act.

Whether the Court should decide at the writ stage whether a single notice could club multiple financial years and whether the demand was barred by limitation under Section 74.

Section 107 of the CGST Act provides a statutory appellate remedy.

The Court considered the principle that issues capable of being effectively examined by the statutory appellate authority may be left to that remedy, while directing the proper officer to consider the petitioner’s reply, afford a personal hearing, and issue a reasoned order.

Section 74 was relevant to the petitioner’s limitation challenge, but the Court did not determine its application or decide the legality of clubbing multiple financial years.

The authorities cited by the parties, including *Mathur Polymers*, *UBS Exports International* and *State Bank of India v. Commercial CGST & CE*, were recorded as submissions; the Court did not adopt or resolve their competing positions on the merits.

The Court took the prima facie view that limitation, jurisdiction and the permissibility of clubbing different financial years involved disputed questions of fact and law that could be more effectively adjudicated by the appellate authority.

Rather than rule on those questions, it directed the petitioner to file a comprehensive reply to the notice and required respondent No. 3 to consider it, provide a personal hearing and pass a reasoned order.

The Court expressly left the merits open and directed the respondent to decide independently, uninfluenced by the Court’s observations.

The petitioner was directed to file a detailed reply within five weeks, and respondent No. 3 was directed to decide it within four weeks of receipt, after a personal hearing, and communicate the decision within a further week.

The respondents were restrained from giving effect to the demand until the decision attained finality; that protection would stand vacated if the petitioner failed to file a reply before 30 November 2026.

The authority was to make an independent decision, and the petitioner was directed not to seek unnecessary adjournments.