Introduction

This judgment of the Kerala High Court reiterates the settled legal principle that a composite Show Cause Notice (SCN) and a composite Order-in-Original covering multiple assessment years are not legally sustainable under the GST law. The Court reaffirmed that each financial year constitutes a separate assessment period requiring an independent Show Cause Notice and separate adjudication.

Relying upon the binding Division Bench decisions in Joint Commissioner (Intelligence & Enforcement) v. M/s. Lakshmi Mobiles Accessories and Tharayil Medicals (M/s.) v. Deputy Commissioner, Thrissur, the Court quashed both the composite Show Cause Notice and the consequential Order-in-Original. However, to balance the interests of the Revenue, the Court permitted fresh proceedings through separate notices for each assessment year and directed exclusion of the intervening period while computing limitation.