M/S S.R.S Travels And Logistics Private Limited vs. Deputy Commissioner Of Commercial Taxes
Held
The High Court held that clubbing multiple tax periods/financial years in a single show cause notice issued under Section 73/74 of the CGST/KGST Act is illegal and invalid. Consequently, the impugned notices and proceedings were quashed.
Facts
The petitioner challenged a show cause notice and an order-in-original issued by GST authorities. The core issue was the consolidation of multiple tax periods/financial years into 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. 28256 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. 28256 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, KALASIPALYAM, BANGALORE-560 092. REPRESENTED BY ITS, MANAGING DIRECTOR SMT.MEGHA BANGALORE RAJASHEKHARA D/O LATE K T RAKASHEKHARA 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:
DEPUTY COMMISSIONER OF COMMERCIAL TAXES (AUDIT)-3.1, DGSTO-3, II FLOOR,
BMTC BUILDING, SHANTI NAGAR,
BANGALORE-560 027. 2. COMMERCIAL TAX OFFICER (ENF-22), SOUTH ZONE,
O/O, THE ADDITIONAL COMMISSIONER OF COMMERCIAL TAXES(ENFORCEMENT) SOUTH V T K -2 BUILDING, RAJENDRANAGARA, KORAMANGALA,
BENGALURU-560 047. B M Loc
The judgment continues below.
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