Sate Bank of India Through its Authorized Signatory Debabrata Bhowmick UBR LEGAL ADVOCATES vs Union of India Through the Secretary Ministry of Finance and ors Advocate - Sangeet Yadav — WP/10267/2025

SUMMARY: WP/10267/2025 - State Bank of India v. Union of India Court: High Court of Bombay (Judges: G.S. Kulkarni and Aarti Sathe, JJ.) Date: 17 April 2026 Case Status: REFERRED TO LARGER BENCH The court did not decide the petition on merits but instead referred the matter to a Larger Bench, noting conflicting judicial precedents on a critical GST law issue. --- CORE ISSUE Whether the GST Department can issue a single consolidated show-cause notice covering multiple financial years under Sections 73 and 74 of the Central Goods and Services Tax (CGST) Act, 2017. --- KEY HOLDING The petition was not dismissed. Instead, the court found: 1. Conflicting High Court decisions exist on whether consolidated notices are permissible 2. Supreme Court dismissals of special leave petitions in *Mathur Polymers* (7 Nov 2025) and *Ambika Traders* (1 Sept 2025) suggest the practice may be valid 3. Significant legal questions require clarification by a Larger Bench --- FIVE QUESTIONS REFERRED TO LARGER BENCH 1. Whether sub-section (10) of Sections 73/74 (limiting order issuance to 3-5 years) restricts the power to issue consolidated notices 2. Whether sub-section (10) *per se* prohibits consolidated show-cause notices for multiple financial years 3. Effect of Section 160 (curing defects) on consolidated proceedings 4. Whether the *Milroc Good Earth Developers* decision (holding consolidated notices invalid) states correct law 5. Legal position established by Supreme Court's *Mathur Polymers* order under Article 141 --- INTERIM RELIEF All interim orders previously granted to petitioners shall continue until the Larger Bench decides the issues. This case analysis is maintained by casestatus.in based on publicly available court records.