Sheth Creators Sun Vision Private Limited PDS LEGAL vs The Union of India — WP/246/2026

CASE SUMMARY: WP/246/2026 Case Name: Sheth Creators Sun Vision Pvt. Ltd. v. The Union of India & Others Court: Bombay High Court (Civil Appellate Jurisdiction) Judges: G.S. Kulkarni and Aarti Sathe, JJ. Date: 17 April 2026 OUTCOME The batch of petitions has been referred to a Larger Bench for reconsideration of the issue. The court did NOT finally decide whether consolidated show-cause notices covering multiple financial years are permissible under the CGST Act, 2017. Instead, it identified significant legal questions requiring reconsideration and referred the matter for a larger bench hearing. KEY ISSUE Whether the GST Department can issue a single consolidated show-cause notice covering multiple financial years under Sections 73/74 of the CGST Act, 2017, or whether separate notices must be issued for each financial year. MAIN FINDINGS - The court found conflicting judicial precedents: Some High Courts (Goa, Madras, Kerala, Karnataka) held consolidated notices impermissible; others (Delhi, Allahabad) held them permissible - The Supreme Court dismissed Special Leave Petitions in *Mathur Polymers* and *Ambika Traders* without interfering with Delhi HC decisions allowing consolidated notices - The court identified no statutory language explicitly prohibiting consolidated notices and noted that Sections 73(3) and 74(3) contemplated notices "for any period" - The limitation period in subsection (10) applies to passing orders, not to issuing show-cause notices, which are separate statutory concepts REFERRED QUESTIONS FOR LARGER BENCH 1. Whether subsection (10) controls subsection (1) to bar consolidated notices 2. Whether subsection (10) per se prohibits consolidated notices for multiple years 3. Effect of Section 160 on consolidated notice proceedings 4. Whether the *Milroc* decision correctly states the law 5. Legal position under Article 141 of the Constitution following the Supreme Court's *Mathur Polymers* order Status: All interim orders continue pending the larger bench decision. This case analysis is maintained by casestatus.in based on publicly available court records.