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

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.