High Court of Calcutta
State Bank of India v. Commercial CGST & CE, SLG Commissionerate
WPA NO. 433 OF 2026
The ruling in brief
Where petitioner bank received a composite show-cause notice and adjudication order clubbing multiple financial years for alleged IGST liability involving fraud, since each financial year is a separate unit for limitation and notices cannot combine multiple years to overcome bar of limitation, such composite notice and order were held illegal and without jurisdiction and were quashed
Provisions considered
Section 74 of Central Goods and Services Tax Act, 2017/West Bengal Goods and Services Tax Act, 2017
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