Multiple Tax Years Cannot be Clubbed in One GST Show-Cause Notice: Calcutta HC Quashes ₹10.97 Crore GST Notice Against SBI Covering Six Financial Years
The Court held that under Section 74, CGST Act, each financial year is a separate unit for tax determination, and limitation periods apply independently. It found that the respondent-GST Authorities acted illegally by issuing a consolidated notice and ignoring documentary evidence provided by State Bank of India (SBI). Consequently, the impugned show-cause notice and order were declared void and without jurisdiction.