Renault India Pvt Ltd vs Union of India — WP/6902/2025

CASE SUMMARY: WP/6902/2025 - Renault India Pvt Ltd v. Union of India OUTCOME Case Referred to Larger Bench – The petitions were not finally decided on merits but instead referred to a Larger Bench to resolve conflicting High Court decisions on a critical issue of GST law. KEY ISSUE 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 Act, 2017. CURRENT HOLDING The Division Bench (Kulkarni & Sathe, JJ.) found grave doubts about petitioners' arguments and indicated that: - Consolidated show-cause notices for multiple financial years appear permissible under the CGST Act - Subsection (10)'s limitation period does NOT restrict subsection (1)'s power to issue notices - The legislature deliberately used broader language ("for any period") in notice provisions versus "financial year" in limitation provisions CONFLICTING JURISPRUDENCE - Milroc Good Earth Developers & others: Consolidated notices impermissible - Delhi High Court (Mathur Polymers, Ambika Traders) & Allahabad High Court: Consolidated notices permissible - Supreme Court: Dismissed appeals challenging the Delhi HC view (Nov 2025) FIVE QUESTIONS REFERRED TO LARGER BENCH 1. Does subsection (10) limit subsection (1)'s scope? 2. Does subsection (10) prohibit consolidated notices per se? 3. Effect of Section 160 on consolidated notices? 4. Is Milroc's reasoning correct? 5. What is the legal position post-Supreme Court's Mathur Polymers dismissal? This case analysis is maintained by casestatus.in based on publicly available court records.