NARAYANA RAMA BHAT v. THE DEPUTY COMMISSIONER OF STATE TAX (INTELLIGENCE) & ORS.

Introduction

This judgment reiterates that a composite adjudication order covering multiple financial years under the CGST Act is not legally sustainable. The Kerala High Court held that each financial year constitutes a separate assessment period requiring an independent order of determination. The Court directed the tax authorities to pass separate orders for each financial year after granting an opportunity of personal hearing and adequate time to file replies wherever necessary.

Background of the Case

The petitioner challenged proceedings initiated pursuant to a show cause notice issued under Section 74(1) of the CGST Act covering multiple financial years.