GSTN Advisory for Furnishing of Bank Account Details as per Rule 10A
As per Rule 10A, taxpayers (except those registered under TCS, TDS, or suo-moto registrations) must furnish their bank account details within 30 days of the grant of registration or before filing details of outward supplies in GSTR-1 or IFF, whichever is earlier.
The changes with respect to Rule 10A will be implemented on the GST Portal soon. Therefore, taxpayers who have not yet furnished their bank account details are advised to update them at the earliest to avoid suspension of their GST Registration and disruption of business activities.
Bank account details can be added through a non-core amendment by navigating to:
Services > Registration > Amendment of Registration Non-Core Fields
CBIC’s Letter on Bunching of Multiple Financial Years into a Single Notice under GST
It has been noticed that several writ petitions have been filed before different Hon’ble High Courts across the country challenging the legality, constitutionality, and validity of the issuance of a consolidated demand notice covering multiple financial years. The contention raised in such petitions is that sections 73 and 74 of the CGST Act, 2017, do not permit such issuance and that the same is contrary to the principles of natural justice. As this issue is recurring, the standard policy comments of the GST Policy Wing on the subject are enclosed at Annexure A for further necessary action.
These issues with the approval of the Member (GST).
Annexure A
Policy Comments on Composite Show Cause Notices Covering Multiple Financial Years under Sections 73/74 of the CGST Act, 2017
This is with reference to various communications received from field formations seeking the Board’s comments on writ petitions filed before various courts across the country. It has been observed that the ground of challenge pertains to the legality of issuing composite Show Cause Notices (SCNs) covering multiple financial years, and whether such issuance is permissible under sections 73 and 74 of the CGST Act, 2017. Accordingly, a comprehensive list of topics, along with policy comments from this office, is elaborated below:
1. Composite SCNs for Multiple Financial Years are Legally Permissible under Sections 73/74
1.1 Statutory Basis
A detailed examination of provisions reveals that the statute does not prescribe any restriction regarding the period for which a demand notice may be issued.
Relevant provisions:
Section 73(1), 73(3), 74(1) and 74(3) are reproduced below for reference:
Section 73(1), CGST Act, 2017:
“Where it appears to the proper officer that any tax has not been paid or short paid or erroneously refunded, or where input tax credit has been wrongly availed or utilised for any reason, other than the reason of fraud or any willful-misstatement or suppression of facts to evade tax, he shall serve notice…”
Section 73(3), CGST Act, 2017:
“Where a notice has been issued for any period under sub-section (1), the proper officer may serve a statement… for such periods other than those covered under sub-section (1).”
Section 74(1) and 74(3), CGST Act, 2017:
Similar language applies in cases involving fraud, wilful misstatement, or suppression.
(Full statutory extract retained as in original text)
1.2 Interpretation
A conjoint reading makes it clear that:
No express bar exists for issuing a consolidated SCN covering multiple financial years.
Issuing a single notice instead of multiple notices promotes administrative efficiency.
The process benefits the taxpayer by reducing duplication and ensuring a single adjudication process.
Thus, the statutory prayer raised by petitioners lacks legal foundation.
2. Composite SCNs Do Not Violate Limitation under Sections 73/74
2.1 Limitation Computed Year-wise
Under Section 73(10) and Section 74(10):
The limitation applies to each financial year separately.
Consolidation does not extend the limitation period.
Each year stands on its own footing for limitation.
2.2 Administrative Logic
Issuing multiple SCNs on identical facts serves no purpose.
Consolidation avoids duplication of proceedings.
It benefits tax administration and taxpayers equally.
3. Interpretation of “Tax Period” and “Any Period” under Sections 73/74
3.1 “Tax Period” vs “Financial Year”
“Tax period” relates to the period for which return is filed.
Issuance of SCN is not tied to a single financial year.
The Act permits SCNs for any period, including multiple years, if the grounds are the same.
3.2 Legal Basis
Sections 73(3), 73(4), 74(3), and 74(4) use the terms “any period” and “such periods”.
Statements issued subsequently are deemed notices if based on the same grounds.
.
3.3 Judicial Support: Ambika Traders Case
Delhi High Court in Ambika Traders v. Additional Commissioner, Adjudication, DGST, W.P.(C) 4853/2025 dated 29 July 2025 held:
“A consolidated notice is not merely permissible but required in such cases… the language of the provision itself does not prevent issuance of SCN or order for multiple years in a consolidated manner.”
The Court recognised the nature of fraudulent ITC transactions, which often span multiple financial years.
4. Judgments in Titan Company Ltd. and Tharayil Medicals Are Not Binding Pan-India
4.1 Territorial Jurisdiction
Decisions by the Madras and Kerala High Courts apply only within their jurisdiction.
Under Articles 226 and 227, such decisions do not create binding precedent for other States/UTs.
The Supreme Court in Dunlop India Ltd. (1985) and Bhag Singh (2004) clarified this principle.
4.2 Contrary Judicial Views
Several High Courts have upheld consolidated SCNs, including:
Rio Care India Pvt. Ltd.
XL Interiors
Ambika Traders (Delhi HC)
Provided the limitation is honoured year-wise.
5. Composite SCNs and the Principle of Severability (AIR 1956 SC 130)
5.1 Supreme Court Precedent
In State of J&K vs. Caltex (India) Ltd., the Supreme Court held:
A composite order covering multiple periods may be segregated.
Valid portion can be upheld even if a part is invalid.
5.2 Practical Outcome
Courts must adopt segmented adjudication.
Taxpayers cannot invalidate the entire proceedings solely because of a composite notice.
5.3 Application in GST
SCNs covering multiple years do not prejudice taxpayers.
They maintain the ability to:
respond year-wise,
avail amnesty year-wise,
contest liability separately.
Thus, principles of natural justice are satisfied.
6. Impact on Benefits: Amnesty Scheme & Compounding
6.1 Amnesty under Section 128A
Taxpayers do not lose amnesty benefits merely because an SCN covers multiple years.
Circular No. 248/05/2025-GST dated 27.03.2025 clarifies that:
Payment may be made only for eligible years (2017-18 to 2019-20),
Remaining years can be contested normally.
This aligns with Rule 164(4) and Rule 164(7).
6.2 Compounding under Section 138
Consolidation does not affect right to compound offences.
The Compounding amount is calculated as a percentage of the tax involved.
Consolidation affects only the computation basis, not eligibility.
Subject to restrictions mentioned in Section 138(1).
7. Validity of Proceedings under Section 160 of The CGST Act
7.1 Savings Clause
Section 160(1) provides that no notice or proceedings shall be invalid merely due to any mistake, defect, or omission, if substantially correct in law.
7.2 Substantive Compliance
Even if consolidation is treated as an irregularity:
It does not render SCN void.
Proceedings are valid if they follow the Act, meet the limitations, and protect revenue.
7.3 Waiver of Technical Objections
Under Section 160(2), if the taxpayer has acted on the notice, later technical objections on form/service are barred.
Conclusion
The legal and procedural framework under the CGST Act, 2017 fully permits issuance of consolidated SCNs for multiple financial years, provided:
The limitation is maintained for each financial year, and
The principles of natural justice are ensured through clear disclosure of year-wise demand.,
Composite SCNs:
enhance administrative efficiency,
avoid multiplicity of proceedings,
do not prejudice taxpayer rights,
allow benefits such as amnesty or compounding without restriction.