TIPL JMMIPL JV Pvt Ltd UBR LEGAL ADVOCATES vs Union of India Through the Revenue Secretary ) Ministry of Finance Department of Revenue AND ORS — WP/17159/2025

SUMMARY OF WP/17159/2025 Case: TIPL JMMIPL JV Pvt Ltd v. Union of India & Others Court: High Court of Judicature at Bombay (Division Bench: G.S. Kulkarni & Aarti Sathe, JJ.) Date: 17 April 2026 Key Outcome: Case REFERRED TO LARGER BENCH for determination of substantial questions of law regarding consolidated GST show-cause notices. --- CENTRAL ISSUE Whether the GST Department can issue a single consolidated show-cause notice covering multiple financial years under Sections 73/74 of the CGST Act, 2017. --- COURT'S DECISION The Division Bench did not decide the petitions on merits but instead identified a conflict of judicial opinion among High Courts requiring resolution by a Larger Bench. Five Questions Referred to Larger Bench: 1. Whether Section 73(10)/74(10) limitation provisions control issuance of consolidated notices 2. Whether sub-section (10) per se prohibits consolidated notices for multiple years 3. Effect of Section 160 on such proceedings 4. Whether *Milroc Good Earth Developers* decision (which invalidated consolidated notices) lays down correct law 5. Legal position after Supreme Court's order in *Mathur Polymers* --- CONFLICTING JUDICIAL POSITIONS Against Consolidated Notices: - *Milroc Good Earth Developers v. Union of India* (Bombay HC) - Courts in Kerala, Karnataka, Madras For Consolidated Notices: - Delhi High Court (*Mathur Polymers*, *Ambika Traders*) - Allahabad High Court (*S.A. Aromatics*) - Supreme Court dismissed SLP in *Mathur Polymers* (7 Nov 2025) without finding "good ground" to interfere --- INTERIM ORDER All interim orders previously passed shall continue until the Larger Bench decides the issues. This case analysis is maintained by casestatus.in based on publicly available court records.