Madras High Court
WP/39903/2026 of T PRAVEEN KUMAR Vs THE ASSISTANT COMMISSIONER OF GST AND CENTRAL EXCI on 7 October 2026
WP No. 39903 of 2026
IN THE HIGH COURT OF JUDICATURE AT MADRAS
DATED: 07-10-2026
CORAM
THE HON'BLE MR JUSTICE KRISHNAN RAMASAMY
WP No. 39903 of 2026
CNR:{HCMA012353682026}
AND
WMP NO. 44867 OF 2026
T Praveen Kumar
No. 16, A.K.T. Thottam,
JPR Nagar, Vellingapattari,
Kancheepuram 631 501
..Petitioner(s)
Vs
The Assistant Commissioner Of Gst And Central Excise Office of the GST and Central Excise, Maraimalai Nagar, Plot No. 40, Ranga Colony, Rajakilpakkam, Chennai 600 073
..Respondent(s)
Prayer:
Writ Petition filed under Article 226 of the Constitution of India, praying for issuance of Certiorarified Mandamus, Calling for the records relating to the impugned order passed by the Respondent bearing DIn No 20260759XL0000847480, being order in original No 116/2026 dated 24.07.2026 as subsequently modified by Corrigendum dated 31.7.2026 quash the same and consequently, direct the Respondent to reconsider the matter afresh by permitting the petitioner to submit all relevant records, documents and objections For Petitioner(s):
Mr.Prashanth Kiran V
For Respondent(s):
Mr.A.P.Srinivas, Sr.St.counsel
WP No. 39903 of 2026
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Order
This writ petition has been filed challenging the impugned order dated 24.07.2026 passed by the respondent.
2. When this writ petition was taken up for hearing, the learned counsel for the petitioner and the learned counsel for the respondent would submit that the issue involved in the present petition is with regard to the bunching of show cause notice/orders, i.e., issuance of single show cause notice/orders for more than one financial year.
3. Further, they would submit that the aforesaid issue has already been decided by this Court vide common order dated 21.07.2025 passed in W.P.Nos.29716 of 2024, etc., batch, wherein it has been held as follows: “28. (i) The GST Act permits only for issuance of show cause notice based on the tax period. Therefore, if the annual return is filed, the entire year would be considered as a tax period and accordingly, the show cause notice shall be issued based on the said annual returns.
(ii) If show cause notice is issued before the filing of annual returns, the same can be issued based on the filing of monthly returns;
(iii) If show cause notice is issued after the filing of annual returns or after the commencement of limitation, the said
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notice shall be issued based on the annual returns with regard to the relevant financial year.
(iv) No show cause notice can be clubbed and issued for more than one financial year since the same is impermissible in law.
(v) In these cases, without any jurisdiction, the impugned show cause notices/orders came to be issued/passed for more than one financial year, which is impermissible in law and hence, the same is liable to be quashed. Accordingly, the impugned show cause notices/orders stand quashed based on the aspect of clubbing of show cause notices for more than one financial year.”
4. Therefore, considering the submissions made by the learned counsel for the petitioner and by following the aforesaid order dated 21.07.2025 passed in W.P.Nos.29716 of 2024, etc., batch, this Court holds that in this case, without any jurisdiction, the impugned order came to be passed for more than one financial year, i.e., for the AY 2020-2021 to 2023-2024, which is impermissible in law and hence, the same is liable to be quashed.
5. Accordingly, this Court passes the following order:
(i) The impugned assessment order dated 24.07.2026 is quashed.
(ii) The respondent is granted liberty to initiate separate proceedings, against the petitioner, for each financial year, within a period of 4 weeks from the date of receipt of a copy of
WP No. 39903 of 2026
this order or prior to the date of expiry of limitation for each financial year, whichever is later.
6. With the above directions, this writ petition is disposed of. No cost. Consequently, the connected miscellaneous petition is also closed. 07-10-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No nsa To The Assistant Commissioner Of Gst And Central Excise Office of the GST and Central Excise, Maraimalai Nagar, Plot No. 40, Ranga Colony, Rajakilpakkam, Chennai 600 073
WP No. 39903 of 2026
KRISHNAN RAMASAMY J. nsa WP No. 39903 of 2026 07-10-2026