Parinee Realty Pvt Ltd LUMIERE LAW PARTNERS vs Union of India — WP/5271/2025

Case under Central Goods and Services Tax Act,2017 Section 74. Next hearing: 29th July 2026.

Next hearing 29-Jul-2026

CNR: HCBM020416742025

e-Filing Number

18-12-2025

Filing Number

WP/41673/2025

Filing Date

19-Dec-2025

Registration No

WP/5271/2025

Registration Date

24-Dec-2025

Judge

Hon'ble The Chief Justice , Hon'ble Shri Justice Suman Shyam

Coram

Hon'ble The Chief Justice , Hon'ble Shri Justice Suman Shyam

Bench Type

Division

Category

INDIRECT TAXES ( 17 )

Sub-Category

GST Goods and Services Tax ( 100 )

Judicial Branch

Original

Last updated 27-May-2026

Acts & Sections

Central Goods and Services Tax Act,2017 Section 74

Petitioner(s)

  1. 1.Parinee Realty Pvt Ltd LUMIERE LAW PARTNERS

Respondent(s)

  1. 1.Union of India

  2. 2.The Commissioner CGST, Mumbai West

  3. 3.The Joint Commissioner, CGST, Mumbai West

Case History

  1. 29-Jul-2026

    Next hearingPending

  2. 29-Jul-2026

    Due Admission - 1

    Hon'ble The Chief Justice , Hon'ble Shri Justice Suman Shyam

  3. 22-Apr-2026

    Hon'ble The Chief Justice,hon'ble Shri Justice Suman ShyamView PDF

  4. 17-Apr-2026

    Hon'ble Shri Justice G. S. Kulkarni,hon'ble Ms Justice Aarti A. SatheView PDF

  5. 17-Apr-2026

    Hon'ble Shri Justice G. S. Kulkarni,hon'ble Ms Justice Aarti A. SatheView PDF

    CASE SUMMARY: WP/5271/2025 Case: Parinee Realty Pvt Ltd v. Union of India & The Commissioner CGST, Mumbai West Court: High Court of Bombay Date: 17 April 2026 Outcome: Petitions dismissed; case referred to Larger Bench for consideration of substantial legal questions. --- Key Issue Whether the GST Department can issue a single consolidated show-cause notice under Sections 73/74 of the CGST Act covering multiple financial years, or whether separate notices must be issued for each financial year. --- Court's Decision The Division Bench (Judges Kulkarni & Sathe) found that: 1. Consolidated notices are permissible – The operation of Section 73(1)/74(1) is not controlled by the limitation period in Section 73(10)/74(10), which governs only the issuance of final orders, not show-cause notices. 2. Each year remains separately time-barred – The consolidated notice does not extend limitation periods; each financial year remains subject to its own 3-year (Section 73) or 5-year (Section 74) limit for issuing orders. 3. Larger Bench referral – Due to conflicting High Court decisions (Bombay's *Milroc* holding against consolidated notices vs. Delhi's *Mathur Polymers* holding in favor, recently upheld by Supreme Court dismissal), the matter is referred to a Larger Bench to settle the law. --- Status All interim orders continued pending Larger Bench decision. This case analysis is maintained by casestatus.in based on publicly available court records.

  6. 18-Feb-2026

    High On Board (Hob)

    Hon'ble Shri Justice G. S. Kulkarni , Hon'ble Ms Justice Aarti A. Sathe

  7. 13-Feb-2026

    Hon'ble Shri Justice G. S. Kulkarni,hon'ble Ms Justice Aarti A. SatheView PDF

  8. 13-Feb-2026

    First hearing

    Initial hearing scheduled

  9. 12-Feb-2026

    Hon'ble Shri Justice G. S. Kulkarni,hon'ble Ms Justice Aarti A. SatheView PDF

  10. 19-Dec-2025

    Case filed

    Registration No. WP/5271/2025

casestatus.in Summary

CASE SUMMARY: WP/5271/2025 Case: Parinee Realty Pvt Ltd v. Union of India & The Commissioner CGST, Mumbai West Court: High Court of Bombay Date: 17 April 2026 Outcome: Petitions dismissed; case referred to Larger Bench for consideration of substantial legal questions. --- Key Issue Whether the GST Department can issue a single consolidated show-cause notice under Sections 73/74 of the CGST Act covering multiple financial years, or whether separate notices must be issued for each financial year. --- Court's Decision The Division Bench (Judges Kulkarni & Sathe) found that: 1. Consolidated notices are permissible – The operation of Section 73(1)/74(1) is not controlled by the limitation period in Section 73(10)/74(10), which governs only the issuance of final orders, not show-cause notices. 2. Each year remains separately time-barred – The consolidated notice does not extend limitation periods; each financial year remains subject to its own 3-year (Section 73) or 5-year (Section 74) limit for issuing orders. 3. Larger Bench referral – Due to conflicting High Court decisions (Bombay's *Milroc* holding against consolidated notices vs. Delhi's *Mathur Polymers* holding in favor, recently upheld by Supreme Court dismissal), the matter is referred to a Larger Bench to settle the law. --- Status All interim orders continued pending Larger Bench decision. This case analysis is maintained by casestatus.in based on publicly available court records.

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