M/s. Marfani Steel Impex v. Principal Commissioner, CGST & Central Excise, Nagpur & Others

Background of the Case

In this case, the petitioner, M/s. Marfani Steel Impex, challenged the validity of a Show Cause Notice (SCN) issued under Section 74 of the CGST Act, 2017. The notice alleged suppression of taxable turnover and short payment of Central GST and sought recovery of tax, interest, and penalty. The controversy arose because the department issued a single consolidated show cause notice covering a period from April 2018 to March 2024, thereby clubbing several financial years and tax periods into one proceeding.

The petitioner contended that the GST law is structured around annual tax periods and financial-year-wise compliance. According to the petitioner, each financial year constitutes a separate unit for purposes of return filing, determination of tax liability, limitation, assessment, adjudication, and recovery. Therefore, issuance of a single show cause notice for multiple financial years was contrary to the statutory framework of the CGST Act.