State Bank of India UBR LEGAL ADVOCATES vs Union of India — HCBM20136072025

SUMMARY This batch of writ petitions challenges consolidated show-cause notices issued under Sections 73/74 of the Central Goods and Services Tax (CGST) Act, 2017, which bundle multiple financial years together. The petitioners argue this violates statutory provisions requiring separate period-wise assessments. COURT ORDER: PETITION DISMISSED WITH REFERENCE TO LARGER BENCH Key Finding: The Division Bench of the Bombay High Court (Justices G.S. Kulkarni and Aarti Sathe) dismissed the petitions but referred critical questions to a Larger Bench, finding: 1. Consolidated notices ARE permissible under Sections 73/74 read with sub-sections (3)-(4) 2. Limitation periods (sub-section 10) do NOT restrict the power to issue consolidated notices—they apply separately to each financial year 3. The Supreme Court's dismissal of Mathur Polymers Special Leave Petition (7 Nov 2025) supports this view 4. The Division Bench in *Milroc Good Earth Developers* (which prohibited consolidated notices) may not lay down correct law ISSUES REFERRED TO LARGER BENCH 1. Whether sub-section (10) controls sub-section (1) to prohibit consolidated notices 2. Whether sub-section (10) *per se* prohibits consolidated notices for multiple years 3. Effect of Section 160 (error/defect protection) on consolidated notice proceedings 4. Correctness of *Milroc* decision 5. Legal position under Article 141 post-*Mathur Polymers* Supreme Court order STATUS OF CURRENT PETITIONS - Proceedings adjourned pending Larger Bench constitution - Interim orders continue until final decision - No substantive order on merits yet This case analysis is maintained by casestatus.in based on publicly available court records.