Tata Projects Ltd. v. Union of India
In favour of the revenue
The ruling in brief
Tata Projects Ltd. and connected petitioners challenged consolidated show cause notices and consolidated demand orders spanning multiple financial years before the Gauhati High Court in writ petitions decided on 8 June 2026. They argued that sections 73 and 74 of the CGST Act require financial-year-wise segregation of notices and orders, and that composite proceedings breached limitation and fairness. Justice Devashis Baruah held the statutes do not mandate separate notices or orders for each year where a composite demand is raised, provided there is no statutory bar or Article 14 violation. Limitation principles must still be applied period-wise when assessing validity. Consolidated proceedings were upheld and the petitions were dismissed in favour of the revenue. The ruling is useful for CAs advising on multi-year SCNs and composite DRC-07 orders. Not legal advice.
For information only — not legal advice. Read the full judgment and applicable law before relying on this summary.
Provisions considered
- CGST S.73 — Determination of tax not paid or short paid (non-fraud cases).
- CGST S.74 — Determination of tax not paid or short paid involving fraud or suppression.
Source documents
Similar rulings
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