M/S S.R.S Travels And Logistics Private Limited vs. The Additional Director
Held
The High Court held that consolidating multiple tax periods/financial years into a single show cause notice is illegal, invalid, and impermissible under the CGST/KGST Act. Consequently, the impugned notice and subsequent proceedings were quashed.
Facts
The petitioner challenged a show cause notice and an Order-In-Original for reversal of input tax credit. The core issue was the consolidation of multiple tax periods/financial years in a single show cause notice.
Key Issues
Whether clubbing multiple tax periods/financial years in a single show cause notice under Section 73/74 of the CGST/KGST Act is permissible and valid in law.
Sections Cited
Section 73, Section 74
AI-generated summary — verify with the full judgment below
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HC-KAR NC: 2025:KHC:54581 WP No. 27928 of 2024
IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 19TH DAY OF DECEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 27928 OF 2024 (T-RES) BETWEEN:
M/S S.R.S TRAVELS AND LOGISTICS PRIVATE LIMITED REGISTERED UNDER COMPANIES ACT OF 1956, NO 321, TSP ROAD, OPPOSITE TO BANGALORE MEDICAL COLLEGE, KALASIPALAYAM, BANGALORE- 560 092. REPRESENTED BY ITS, MANAGING DIRECTOR SMT. MEGHA BANGALORE RAJASHEKHARA D/O LATE K.T.RAJASHEKHARA AGED ABOUT 47 YEARS OFFICE AT NO. 321, TSP ROAD, OPPOSITE TO BANGALORE MEDICAL COLLEGE, KALASIPALYAM, BENGALURU – 560 002. …PETITIONER (BY SMT. VINITHA.M, ADVOCATE FOR SRI. P.B. HARISH, ADVOCATE)
AND:
THE ADDITIONAL DIRECTOR
OF GST INTELLIGENCE DIRECTORATE GENERAL OF GST INTELLIGENCE,
BENGALURU ZONAL UNIT,
O/O, THE PRINCIPAL ADDITIONAL DIRECTOR GENERAL,
NO 112, S P ENCLAVE,
ADJACENT TO KARNATAKA BANK,
K H ROAD,
BENGALURU-560 027. 2. THE DEPUTY COMMISSIONER
OF COMMERCIAL TAXES B M Location: High
The judgment continues below.
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