Karnataka HC Reaffirms: Composite SCN for Multiple Financial Years Is Permissible — Revenue Wins Back Orders Quashed by Single Judge

The Karnataka High Court Division Bench has once again applied its April 2026 ruling in W.A. No. 1751/2024 to restore an SCN and original order that had been quashed by a Single Judge on the ground that a composite show cause notice covering multiple financial years is impermissible under the CGST Act. The writ appeal judgment, by Justice S.G. Pandit and Dr. Justice K. Manmadha Rao in Writ Appeal No. 1354 of 2026 (Union of India v. Educational Rating and Assessment Foundation, decided 30.07.2026), forms part of a growing body of Division Bench orders reversing Single Judge decisions that had followed the now-overruled view in M/s Pramur Homes and Shelters.

The background is now familiar to practitioners in Karnataka. A Single Judge had quashed an SCN dated 30.03.2022 under Section 74 of the CGST Act along with the Order-in-Original, corrigendum, summary and the Order-in-Appeal in terms of the December 2025 judgment in M/s Pramur Homes and Shelters (W.P. No. 33081/2025), which had held that a common show cause notice covering multiple tax periods is legally impermissible. Revenue appealed. The Division Bench, after hearing both sides, allowed the appeal following W.A. No. 1751/2024 — its own April 2026 ruling which had taken the contrary and authoritative position that a composite SCN for multiple financial years is permissible under the Act.

Two subsidiary points are also noteworthy. First, the Division Bench observed that since the respondent-assessee had challenged not just the SCN and OIO but also the Appellate Order, the appropriate remedy would have been to file an appeal before the GSTAT rather than approach the Single Judge in writ jurisdiction. Second — and practically important — the Division Bench granted the assessee six weeks to file an appeal before the GSTAT, with a direction to the Tribunal to entertain it without raising any question of limitation. This ensures the assessee is not prejudiced by the time spent in litigation up to this point.

The practical consequence is that all taxpayers in Karnataka who had SCNs and orders quashed on the Pramur Homes principle should be aware that those orders are now liable to be reversed on Revenue's writ appeal. The composite SCN position in Karnataka is settled by the Division Bench in W.A. 1751/2024, and practitioners facing fresh composite SCNs should address their defence on merits rather than on the jurisdictional objection.

-2026-juristway.com-2219-HC(Karnataka)-GST  |  High Court of Karnataka | Writ Appeal No. 1354 of 2026  |  30.07.2026