M/S Attica Gold Private Limited vs. The Joint Commissioner Of Central Tax.
Held
The High Court held that consolidating multiple tax periods/financial years into a single show cause notice under Section 74 of the CGST Act is illegal, invalid, and impermissible. Consequently, the impugned notices and subsequent proceedings were quashed.
Facts
The petitioners challenged show cause notices and orders issued under the CGST Act, which consolidated multiple tax periods/financial years into a single notice. The respondents issued these notices and orders for tax periods ranging from July 2017 to March 2023.
Key Issues
The primary issue was whether clubbing multiple tax periods/financial years in a single show cause notice under the CGST Act is legally permissible.
Sections Cited
Section 74, Section 73
AI-generated summary — verify with the full judgment below
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HC-KAR NC: 2025:KHC:54354 WP No. 12903 of 2025
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.12903 OF 2025 (T-RES) BETWEEN:
M/S ATTICA GOLD PRIVATE LIMITED REGISTERED UNDER COMPANIES ACT, 2013
REPRESENTED BY ITS DIRECTOR
SRI. AYUB MOHAMMED SALMAN
SON OF SRI. SYED PASHA AYUB,
AGED ABOUT 28 YEARS,
NO,11/4. SUVARNA BHAWAN,
QUEEN'S ROAD,
BANGALORE – 560 052. 2. M/S. ATTICA GOLD PRIVATE LIMITED, REGISTERED UNDER COMPANIES ACT,
2013 REPRESENTED BY ITS DIRECTOR
SRI. AYUB MOHAMMED SALMAN
SON OF SRI. SYED PASHA AYUB,
AGED ABOUT 28 YEARS,
NO.1 A, OPP. SRI KRISHNA TEMPLE,
TALUK OFFICE ROAD,
NEAR GRT BYE PASS, HOUSR,
KRISHNAGIRI,
TAMIL NADU-635 109. 3. M/S. ATTICA GOLD PRIVATE LIMITED, REGISTERED UNDER COMPANIES ACT
REPRESENTED BY ITS DIRECTOR
SRI. AYUB MOHAMMED SALMAN
SON OF SRI. SYED PASHA AYUB,
AGED ABOUT 28 YEARS,
NO.15-2149, 15-2150, MSR JUNCTION,
VELLORE ROAD, CHITTOR,
ANDHRA PRADESH-517 001. 4. M/S. ATTICA GOLD PRIVATE LIMITED, REGISTERE
The judgment continues below.
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