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Full Bench Reference on GST Single SCN for Multiple Years

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1) Whether the operation of sub-section (1) of Section 73/74 of the CGST Act read with the provisions of sub-section (3) is in any manner controlled by the provisions of sub section (10), so as to create an embargo, on the department to issue a consolidated show cause notice for different years ?

2) Whether the provisions of sub-section (10) of Section 73/74 of the CGST Act per se prohibits the issuance of single consolidated show cause notice for multiple financial years/tax periods?

3) What is the effect of Section 160 of the CGST Act on the proceedings initiated by the proper officer under Section(s) 73/74 of the CGST Act by issuance of a consolidated show cause notice for different periods?

4) Whether the decision of the Division Bench in Milroc Good Earth Developers v/s Union of India & Ors., (2026 (104) GSTL 45 (Bombay) 9.10.2025) when it holds that the proper officer lacks authority to club various financial years/tax periods, in issuing a single consolidated show cause notice under Section 73(1) & (3)/74(1) & (3) of CGST Act lays down the correct position in law?

5) In terms of Article 141 of the Constitution of India, what is the legal position as brought about in the order of the Supreme Court in the case of Mathur Polymers (supra)

Judgment dated  17.4.2026  of the High Court of Bombay in Writ Petition No.16848 of 2025 of M/s Rollmet LLP  Vs.   The Union of India and others with connected writ petitions.

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