M/S Century Galaxy Developers Limited vs. The Union Of INDIA
Held
The High Court held that consolidating multiple tax periods/financial years into a single show cause notice issued under Section 73/74 of the CGST/KGST Act is illegal and impermissible. Consequently, the impugned notice and further proceedings were quashed.
Facts
The petitioner challenged a show cause notice issued by the GST authorities. The notice consolidated multiple tax periods/financial years from 2019-20 to 2023-24.
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 legally permissible and valid.
Sections Cited
Section 73, Section 74
AI-generated summary — verify with the full judgment below
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HC-KAR NC: 2025:KHC:54660 WP No. 22633 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. 22633 OF 2024 (T-RES) BETWEEN:
M/S CENTURY GALAXY DEVELOPERS LIMITED A COMPANY REGISTERED UNDER THE COMPANIES ACT 1956, REPRESENTED BY ITS DIRECTOR, MR SALILM JAHANGEER KIRMANI, AGED ABOUT 57 YEARS, S/O MOHD. SYED KIRMANI, ADDRESS AT PENT HOUSE, B 9, OLD AIRPORT, KODIHALLI, BANGALORE – 560 008 …PETITIONER
(BY SRI. BHARAT RAICHANDANI, SRI. RAAGHUL PIRAANESH & SRI. CHANDRA KIRAN K., ADVOCATES)
AND:
THE UNION OF INDIA REPRESENTED HEREIN BY THE SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI – 110 001
CENTRAL BOARD OF INDIRECT TAXES AND CUSTOMS REPRESENTED HEREIN BY THE CHAIRMAN, DEPARTMENT OF REVENUE,. MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI – 110 001
THE ADDITIONAL DEPUTY COMMISSIONER OF COMMERCIAL TAXES (ENFORCEMENT) SOUTH ZONE VTK-II, B-BLOCK, RAJENDRA NAGAR,
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