Shemaroo Entertainment Limited vs Union of India — HCBM10025072026

SUMMARY: Shemaroo Entertainment Limited Case Case: Writ Petition (ST) No. 1495 of 2026 (with 30+ consolidated petitions) Petitioner: Shemaroo Entertainment Limited and others Respondents: Union of India, Central Board of Indirect Taxes and Customs, CGST Officials Date: 17 April 2026 --- OUTCOME Petitions DISMISSED with all matters referred to a Larger Bench to resolve a critical question of law: whether consolidated show-cause notices covering multiple financial years are legally permissible under Sections 73/74 of the CGST Act, 2017. --- KEY ISSUE The petitioners challenged consolidated show-cause notices issued under Sections 73/74 of the CGST Act that combined multiple financial years into a single notice, arguing this violates statutory limitation periods and lacks jurisdictional authority. --- COURT'S POSITION The Bench (Kulkarni & Sathe, JJ.) favored the Revenue's position over the earlier Division Bench decision in *Milroc Good Earth Developers*, concluding that: 1. Consolidated notices ARE permissible — Sections 73(1) & 74(1) contain no express prohibition against clubbing multiple periods 2. Subsection (10) limitations apply separately — Each financial year's 3/5-year limitation is tracked independently; consolidation doesn't extend these limits 3. Sections 73(3)-(4) support consolidation — The legislature deliberately permitted statements for "such other periods" beyond the initial notice 4. Distinction between notice-issuance and order-passing — Subsection (10) limits when orders can be passed, not when notices can be issued --- QUESTIONS REFERRED TO LARGER BENCH 1. Whether subsection (10) controls subsection (1)'s operation regarding consolidated notices 2. Whether subsection (10) *per se* prohibits consolidated notices 3. Effect of Section 160 (curing defects) on consolidated proceedings 4. Whether *Milroc* decision correctly states the law 5. Legal position under Article 141 given Supreme Court's dismissal of *Mathur Polymers* SLP --- INTERIM STATUS All existing interim orders remain in force until the Larger Bench decides. This case analysis is maintained by casestatus.in based on publicly available court records.