Sunil Narayan Patil vs The Additional Commissioner CGST and Central Excise, Nashik — WP/2017/2026

SUMMARY OF WP/2017/2026 - SUNIL NARAYAN PATIL v. THE ADDITIONAL COMMISSIONER CGST & ORS Outcome: Petitions DISMISSED and referred to a Larger Bench for reconsideration of fundamental legal questions regarding consolidated show-cause notices under GST law. Key Issues: The primary issue concerned 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. Court's Finding: While acknowledging a conflicting Division Bench precedent (*Milroc Good Earth Developers*), the Court found the issue requires reconsideration by a Larger Bench due to: - Conflicting decisions across High Courts (Delhi, Allahabad, Madras, Karnataka, Kerala) - Supreme Court's dismissal of Special Leave Petitions in *Mathur Polymers* (November 2025) - Significant legal principles regarding statutory interpretation of the CGST Act's machinery provisions Critical Questions Referred to Larger Bench: 1. Whether Section 73(10)/74(10) limitation periods restrict issuance of consolidated notices 2. Whether consolidated notices for multiple years are statutorily prohibited 3. Effect of Section 160 (curative provision) on consolidated proceedings 4. Correctness of the *Milroc* precedent 5. Legal effect of Supreme Court's dismissal order in *Mathur Polymers* Status: Interim orders continue; case adjourned pending Larger Bench constitution. This case analysis is maintained by casestatus.in based on publicly available court records.