The Rajasthan High Court has stayed the composite notice for 6 Financial Years (FY) against Hindustan Zinc.
The bench of Justice Arun Monga and Justice Yogendra Kumar Purohit took note of divergent views between the Delhi High Court and Andhra Pradesh High Court on the validity of issuing a single composite notice covering multiple financial years. Relying on an earlier interim order in Rathi Bars Limited v. Additional Commissioner, the Court stayed the effect and operation of the impugned composite notice.
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During the hearing, counsel for the respondents sought time to file a reply, which the Court granted, listing the matter for further hearing on March 10, 2026. However, the Bench proceeded to examine the interim relief sought by the petitioner, particularly in light of similar disputes pending before various High Courts.
The petitioner drew the Court’s attention to an earlier interim order passed in the case of Rathi Bars Limited v. Additional Commissioner, CGST, where the Jaipur Bench of the same High Court had stayed a similar composite notice. That order had noted conflicting judicial views between the Delhi High Court and the Andhra Pradesh High Court on whether a single show cause notice could validly cover multiple assessment years under GST law.
Taking note of the “divergent views” and the similarity of the controversy, the Jodhpur Bench held that the matter warranted interim protection. Accordingly, it ordered that the “effect and operation” of the impugned composite notice issued to Hindustan Zinc shall remain stayed until further orders.
The ruling underscores a growing judicial concern around procedural propriety in GST enforcement, particularly the practice of issuing consolidated notices for multiple years. While tax authorities have increasingly adopted such measures for administrative efficiency, assessees have challenged them as being contrary to statutory scheme and principles of natural justice.
The case is expected to have broader implications for GST litigation across India, as courts continue to grapple with the legality of multi-year notices amid inconsistent precedents. The final outcome may provide much-needed clarity on whether tax authorities can club multiple assessment periods into a single proceeding or must issue year-wise notices.
Case Details
Case Title: Hindustan Zinc Limited Versus UOI
Case No.: D.B. Civil Writ Petition No. 417/2026
Date: 12/02/2026
Counsel For Petitioner: Sharad Kothari
Counsel For Respondent: Mahaveer Bishnoi, AAG
