M/S M G WADHWANI v. UNION OF INDIA & ORS. – BOMBAY HIGH COURT
High Court, Bombay
Anil L Pansare, Justice & Nivedita P Mehta, Justice
M/S M G WADHWANI
v.
UNION OF INDIA & ORS.
WRIT PETITION NO.3902/2025 dated 13.02.2026
Law : GST
Act Name : Central Goods & Service Tax Act, 2017
Relevant Section : Section 74
Decision : Partly in favour of assessee
Consolidated SCN – Petitioner contented consolidation of several financial years or tax periods in one notice under Section 74 impermissible – Petitioner relied on Milroc Good Earth Developers(2025) and Rite Water Solutions (India) Ltd.( 2025 ) holding holding no scope for consolidating periods under statutory scheme tied to annual returns and limitation under Sections 73/74(10) – Revenue relied on Mathur Polymers(2025) as affirmed in limine by Supreme Court, to justify consolidated notice in cases of alleged fraudulent ITC – Court held dismissal of SLP in limine does not lead to merger, subsequent binding decisions of Bombay High Court prevail for authorities within jurisdiction – Held: Writ petition disposed – SCN & order quashed – Liberty reserved to re issue notices strictly in terms of Section 74.
Represented By:
Counsel for the Petitioner: A.J.Bhoot, Advocate
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