PRABODHAN BAHU UDDESHIYA SANSTHA AND ANR vs THE ADDITIONAL COMMISSIONER CGST AND CENTRAL EXCISE AND ORS — WP/14606/2025

Case Summary: WP/14606/2025 Court: High Court of Bombay (Bombay High Court) Judges: G.S. Kulkarni & Aarti Sathe, JJ. Date: 17 April 2026 Facts The petitioners (Prabodhan Bahu Uddeshiya Sanstha and Sunil Narayan Patil) challenged consolidated show-cause notices issued under Sections 73/74 of the Central Goods and Services Tax Act, 2017 that bunched multiple financial years together in a single notice. Core Issue Whether the GST department can issue a single consolidated show-cause notice covering multiple financial years, or whether separate notices must be issued for each financial year. Outcome The petition was not directly decided on merits. Instead, the Court: 1. Referred the matter to a Larger Bench to resolve conflicting judicial precedents on this issue 2. Stayed all interim orders pending the Larger Bench's decision 3. Identified five critical questions of law requiring clarification regarding Sections 73(10) and 74(10) of the CGST Act and Supreme Court precedent in *Mathur Polymers v. Union of India* Key Observations The Court found "significant legal issues" and a "cleavage of opinion" among High Courts: - Against consolidated notices: Bombay (Milroc), Nagpur (Paras Stone), Kerala, Madras, Karnataka High Courts - Favoring consolidated notices: Delhi High Court, Allahabad High Court; Supreme Court dismissed Special Leave Petitions challenging Delhi HC's view The Court did not decide whether consolidated notices are permissible, leaving this contested question for authoritative resolution by a larger bench. This case analysis is maintained by casestatus.in based on publicly available court records.