CTL Logistics India Private Limited UBR LEGAL ADVOCATES vs Union of India — WP/2031/2026

Summary of WP/2031/2026 (CTL Logistics India Private Limited) Court: Bombay High Court (Division Bench: Justices G.S. Kulkarni and Aarti Sathe) Date: 17 April 2026 Key Issue: Whether consolidated/bunched show-cause notices covering multiple financial years under Sections 73/74 of the CGST Act, 2017 are permissible Order Petitions Dismissed (with direction to constitute Larger Bench) The Court dismissed all petitions in this batch challenging consolidated show-cause notices issued for multiple financial years. However, the Court identified significant legal issues requiring determination by a Larger Bench due to conflicting High Court judgments on this issue. Critical Findings The Division Bench held: 1. Consolidated notices ARE permissible — Sections 73(1) and 74(1) read with Section 73(3)/74(3) do NOT restrict issuance of show-cause notices to single tax periods 2. Limitation provisions (Subsections 10) do NOT restrict notice issuance — Subsection (10) prescribes limitation for passing *orders*, not for issuing notices. These are separate statutory concepts. 3. Nature of ITC disputes justifies consolidation — For fraudulent ITC availment cases, transactions often span multiple years; consolidation enables proper investigation 4. Supreme Court precedent favors consolidation — The Supreme Court's dismissal of the Special Leave Petition in *Mathur Polymers* (7 November 2025) establishes that consolidated notices are valid Questions Referred to Larger Bench 1. Whether subsection (10) controls subsection (1) regarding consolidated notices 2. Whether subsection (10) *per se* prohibits consolidated notices 3. Effect of Section 160 CGST Act on consolidated proceedings 4. Whether *Milroc Good Earth Developers* decision (holding consolidation invalid) is correct 5. Legal position established by Supreme Court's order in *Mathur Polymers* Relief Granted - All interim orders previously passed continue until the Larger Bench decides Status: Case adjourned pending Larger Bench constitution by Chief Justice. This case analysis is maintained by casestatus.in based on publicly available court records.