Ms Mangal Entertainment vs Union of India — HCBM10037692026

Summary of Ms. Mangal Entertainment Case This is a batch of consolidated writ petitions before the Bombay High Court addressing whether the GST Department can issue a single consolidated show-cause notice covering multiple financial years under Sections 73/74 of the Central Goods and Services Tax (CGST) Act, 2017. Case Outcome Petitions referred to a Larger Bench for decision on questions of law. The court did not allow or dismiss the petitions but instead identified significant legal conflicts requiring resolution by a larger bench. Key Issue Whether consolidated show-cause notices bunching multiple financial years are valid or violate Sections 73(10) and 74(10) of the CGST Act, which prescribe separate limitation periods (3 and 5 years respectively) for each financial year. Conflicting Judicial Positions The court identified a "cleavage of opinion": - Against consolidated notices (*Milroc Good Earth Developers* - Bombay; *Madras, Kerala, Karnataka High Courts*): Each financial year is a separate assessment unit; consolidation violates the limitation scheme. - For consolidated notices (*Delhi and Allahabad High Courts*): Sections 73/74 are dispute-based adjudication provisions, not return-based assessments; fraud/ITC cases inherently span multiple years. - Supreme Court: Dismissed SLP in *Mathur Polymers* (Nov 7, 2025) with speaking order supporting consolidated notices. Court's Inclination (Not Binding) The two-judge bench appeared to favor permitting consolidated notices, noting that Sections 73(3)-(4) explicitly authorize issuing statements for "other periods," suggesting legislative awareness of multi-year proceedings. Questions Referred to Larger Bench 1. Whether subsection (10)'s limitation provision controls subsection (1)'s authority to issue consolidated notices 2. Whether subsection (10) *per se* prohibits consolidated notices 3. Effect of Section 160 on such proceedings 4. Whether *Milroc* laid down correct law 5. Legal effect of Supreme Court's *Mathur Polymers* order under Article 141 Interim Relief All interim orders previously granted in these petitions continue until the Larger Bench decides. This case analysis is maintained by casestatus.in based on publicly available court records.