The Karnataka High Court has held that issuing a consolidated or common show cause notice (SCN) for multiple tax periods under Section 74 of the CGST/KGST Act is legally valid.
Setting aside the Single Judge’s order that had quashed the notice, the Division Bench remanded the matter to the Adjudicating Authority to consider the taxpayer’s objections and decide the case in accordance with the law.
The Central Tax authorities have submitted the appeal contesting the order dated 17.12.2025 made by a Single Judge in W.P.No.33952/2025.
In this case, the respondent-taxpayer M/s Ozone Facility Management Pvt. Ltd. asked the writ court to dispute a common SCN u/s 74 of the CGST and KGST Acts, 2017, for various tax periods from 2019-20 to 2023-24.
The Single Judge had approved the writ petition and set aside the notice with liberty to the government to start proper measures under the law.
The revenue is not satisfied with the quashing of the notice and thus approached the division bench. A division court, including Justice S.G. Pandit and Justice Dr K. Manmadha Rao, determined that the basic lawful issue on the validity of a combined SCN has already been addressed by a co-ordinate court of the High Court. The Court put reliance on its landmark judgement rendered on 24 th April, 2026 in W.A.No.1751/2024 and linked cases.
In the above-said precedent, the HC had categorically concluded that issuance of a combined or common show-cause notice is admissible under the GST regime.
Also, it said that where the case is at the phase of filing a response to the SCN, the writ court must not quash the notice but send back the case to the adjudicating authority to examine the objections and pass a proper ruling.
The bench determined that the single judge made a mistake in quashing the show cause notice (SCN), applying the reasons specified in the April 2026 judgement to the facts of the present case.
“Following the above judgment dated 24.04.2026 in W.A.No.1751/2024, the present appeal needs to be allowed,” the Court stated.
The Division Bench approved the writ appeal and quashed the order dated 17.12.2025 of the Single Judge in the result. The case is directed back to the adjudicating authority for raising the objections and further proceedings to provide an appropriate order as per the law.
Read Also: AP HC: Single SCN and Composite GST Order Cannot Be Given for Multiple Tax Periods
The court provides 4 weeks from the order uploading date on the website of the HC to the respondent-assessee to submit its objections to the common SCN on 3rd and 10th September, 2025, for the purpose of furnishing a fair chance.
| Case Title | Assistant Commissioner of Central Tax vs. M/S. Ozone Facility Management Pvt. Ltd |
| Case No. | NO. 1302 OF 2026 (T-RES) |
| Appellants By | Sri. Unnikrishnan M. |
| For Respondent | Sri. Sandeep Huilgol |
| Karnataka High Court | Read Order |
