THE FEDERAL BANK LIMITED v. THE ADDITIONAL DIRECTOR & ORS.

Introduction

This judgment of the Kerala High Court settles an important procedural issue under the GST law regarding the validity of composite Show Cause Notices (SCNs) covering multiple financial years.

The Court held that a single consolidated Show Cause Notice issued for several assessment years is not legally sustainable. Relying upon its earlier Division Bench decisions in Joint Commissioner (Intelligence & Enforcement) v. M/s. Lakshmi Mobiles Accessories and Tharayil Medicals v. Deputy Commissioner, the Court ruled that each assessment year is a separate and independent unit of assessment, requiring an independent Show Cause Notice and separate adjudication.