Shell Apparels Private Limited vs. The Assistant Commissioner
Held
The Court held that clubbing multiple tax periods in 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 under GST law. The core issue was the consolidation of multiple tax periods into a single show-cause notice.
Key Issues
Whether clubbing multiple tax periods in a single show-cause notice is legally permissible. Whether the impugned show-cause notice, which consolidated multiple periods, warrants interference.
Sections Cited
Section 73, Section 74
AI-generated summary — verify with the full judgment below
- 1 -
HC-KAR NC: 2025:KHC:54573 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 17TH DAY OF DECEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 12362 OF 2025 (T-RES) BETWEEN:
SHELL APPARELS PRIVATE LIMITED REPRESENTED BY ITS DULY AUTHORISED MANAGER-ACCOUNTS SRI. CHANDRASHEKAR, SON OF SRI. KRISHNAPPA AGED ABOUT 43 YEARS, NO. 10/14-10/16, GT INDUSTRIAL COMPLEX, MAGADI MAIN ROAD, SUNKADAKATTE, BENGALURU 560 091. …PETITIONER (BY SRI. VENKATESH. G.,ADVOCATE) AND:
THE ASSISTANT COMMISSIONER OF CENTRAL TAX, NORTH WEST DIVISION-4, BMTC BUS STAND BUILDING, BANASHANKARI, BENGALURU 560070
THE ASSISTANT COMMISSIONER OF CENTRAL TAX, AUDIT-II COMMISSIONERATE, OFFICE OF THE COMMISSIONER OF CENTRAL TAX (AUDIT), BENGALURU AUDIT-II JSS TOWERS, 100 FT. RING ROAD, B M Location: High Court of Karnataka HC-KAR NC: 2025:KHC:54573 BANASHANKARI III STAGE, BENGALURU 560085 …RESPONDENTS (BY SRI. AKASH B SHETTY, ADVOCATE)
THIS WP IS FILED UN
The judgment continues below.
Read the full judgment
A free account opens 10 full GST judgments a month (one account works on both bharattax.net and this site). Re-reading one you have already opened does not count again.
The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.
Reproduced from the public record of the Karnataka High Court. Verify against the court's own copy before relying on it. Income tax judgments are on bharattax.net.