1 908...3425-26.odt IN THE HIGH COURT OF JUDICATURE AT BOMBAY NAGPUR BENCH AT NAGPUR WRIT PETITION NO. 3425/2026 KC Overseas Education Private Limited Vs. The Joint Commissioner of CGST and Central Excise Audit Commissionerate, Nagpur and others WITH WRIT PETITION NO. 4820/2026 M/s N G Power Tech Vs. The Superintendent (Audit) CGST Audit Commissionerate and another WITH WRIT PETITION No.2966/2026 M/s IJM India Infrastructure Limited Vs. The Additional Commissioner, Central Tax & Central Excise, Nagpur WITH WRIT PETITION No. 4610/2026 M/s Shyam Trading Company Vs. The Superintendent (Audit), Group – 17 / Circle – VI and others WITH WRIT PETITION NO. 5019/2026 M/s Somani Steels Vs. Joint Direct, DGGI, Nagpur & another WITH WRIT PETITION No. 6482/2026 M/s Nirmay Infratech Vs. Additional Director, Directorate General of GST Intelligence and another WITH WRIT PETITION No. 4534/2026 Office Notes, Office Court's or Judge's orders Memoranda of Coram, Appearances, Court's orders or directions and Registrar's orders WP No. 3425/2026 Mr. Kapil Hirani, Advocate for petitioner Mrs. Ketki Jaltare Vaidya, Adv. for Respondent Nos.1 to 6 Mr. R.D. Heda, Adv.& Mr. Vaiman Chatap, Adv. for petitioner in WP No. 4820/2026 & WP No. 4610/2026 Mr. Viswajeet Singh Uberoi, Adv.& Mr. G. Natrajan, Adv. for petitioner in WP No. 2966/2026 Mrs. Ketki Jaltare Vaidya, Adv. for Respondent Nos.1 and 2 in WP No. 4820/2026

Mr. Kunal Nalamwar, Adv. for Respondent in WP No. 2966/2026 & 4610/2026, 5019/2026 Mr. Abhishek J. Bhoot, Adv. for petitioner in WP No.5019/2026 Mr. Abhishek Kumar, Adv. for petitioner in WP No. 6482/2026 Mrs. Ketki Jaltare Vaidya, Adv. for Respondent Nos.1 & 2 in WP No.6482/2026 CORAM: ANIL L. PANSARE, AND NIVEDITA P. MEHTA, JJ. DATED : 11.09.2026 2 908...3425-26.odt 1. Leave to file reply is granted. 2. Heard. 2. The issue involved is covered by the order passed by us today in Writ Petition No. 2978/2026 (Ganesh Valmik Bawane Vs. Joint Director, Directorae General of GST). The issue pertains to clubbing notice under Section 74 of the Central Goods and Services Tax Act, 2017. We have taken a view that under the law presently prevailing in the Bombay High Court, a single show cause notice under Section 74 of the CGST Act cannot club different financial years / tax periods. Accordingly and for the reasons set out in the case of Milroc Good Earth Developers (supra) and Rite Water Solutions (India) Ltd. (supra), the petitions are partly allowed. The impugned show cause notices are quashed and set aside. However, the respondents are at liberty to reissue notices in terms of the provisions of Section 73 / 74 / 74A of the Act, if there is no other legal impediment. 4. The petitions are disposed of in the above terms with no order as to costs. (NIVEDITA P. MEHTA, J.) (ANIL L. PANSARE, J.) MPDeshpande Signed by: Mr. M.P. Deshpande

Designation: PA To Honourable Judge Date: 15/09/2026 11:18:45

1 908...3425-26.odt IN THE HIGH COURT OF JUDICATURE AT BOMBAY NAGPUR BENCH AT NAGPUR WRIT PETITION NO. 3425/2026 KC Overseas Education Private Limited Vs. The Joint Commissioner of CGST and Central Excise Audit Commissionerate, Nagpur and others WITH WRIT PETITION NO. 4820/2026 M/s N G Power Tech Vs. The Superintendent (Audit) CGST Audit Commissionerate and another WITH WRIT PETITION No.2966/2026 M/s IJM India Infrastructure Limited Vs. The Additional Commissioner, Central Tax & Central Excise, Nagpur WITH WRIT PETITION No. 4610/2026 M/s Shyam Trading Company Vs. The Superintendent (Audit), Group – 17 / Circle – VI and others WITH WRIT PETITION NO. 5019/2026 M/s Somani Steels Vs. Joint Direct, DGGI, Nagpur & another WITH WRIT PETITION No. 6482/2026 M/s Nirmay Infratech Vs. Additional Director, Directorate General of GST Intelligence and another WITH WRIT PETITION No. 4534/2026 Office Notes, Office Court's or Judge's orders Memoranda of Coram, Appearances, Court's orders or directions and Registrar's orders WP No. 3425/2026 Mr. Kapil Hirani, Advocate for petitioner Mrs. Ketki Jaltare Vaidya, Adv. for Respondent Nos.1 to 6 Mr. R.D. Heda, Adv.& Mr. Vaiman Chatap, Adv. for petitioner in WP No. 4820/2026 & WP No. 4610/2026 Mr. Viswajeet Singh Uberoi, Adv.& Mr. G. Natrajan, Adv. for petitioner in WP No. 2966/2026 Mrs. Ketki Jaltare Vaidya, Adv. for Respondent Nos.1 and 2 in WP No. 4820/2026

Mr. Kunal Nalamwar, Adv. for Respondent in WP No. 2966/2026 & 4610/2026, 5019/2026 Mr. Abhishek J. Bhoot, Adv. for petitioner in WP No.5019/2026 Mr. Abhishek Kumar, Adv. for petitioner in WP No. 6482/2026 Mrs. Ketki Jaltare Vaidya, Adv. for Respondent Nos.1 & 2 in WP No.6482/2026 CORAM: ANIL L. PANSARE, AND NIVEDITA P. MEHTA, JJ. DATED : 11.09.2026 2 908...3425-26.odt 1. Leave to file reply is granted. 2. Heard. 2. The issue involved is covered by the order passed by us today in Writ Petition No. 2978/2026 (Ganesh Valmik Bawane Vs. Joint Director, Directorae General of GST). The issue pertains to clubbing notice under Section 74 of the Central Goods and Services Tax Act, 2017. We have taken a view that under the law presently prevailing in the Bombay High Court, a single show cause notice under Section 74 of the CGST Act cannot club different financial years / tax periods. Accordingly and for the reasons set out in the case of Milroc Good Earth Developers (supra) and Rite Water Solutions (India) Ltd. (supra), the petitions are partly allowed. The impugned show cause notices are quashed and set aside. However, the respondents are at liberty to reissue notices in terms of the provisions of Section 73 / 74 / 74A of the Act, if there is no other legal impediment. 4. The petitions are disposed of in the above terms with no order as to costs. (NIVEDITA P. MEHTA, J.) (ANIL L. PANSARE, J.) MPDeshpande Signed by: Mr. M.P. Deshpande

Designation: PA To Honourable Judge Date: 15/09/2026 11:18:45