Precedent and Judicial Discipline

One Tax Period, One Notice: Bombay High Court's Nagpur Bench Reaffirms That a Section 74 GST Notice Cannot Club Multiple Financial Years, Pending a Larger Bench Reference

A show cause notice covering financial years 2019-20 to 2021-22, alleging suppression of taxable value, was quashed because the CGST Act ties assessment and its five-year limitation to each financial year separately. The Bombay High Court held itself bound by its own precedent over a contrary Delhi High Court view — even after the Supreme Court declined to interfere with that view — but preserved the Revenue's liberty to revive the case if a pending Larger Bench reference goes the other way.