The Hon’ble High Court of Delhi allows filling of Consolidated GST Appeal against Order Covering Multiple Years

The Hon’ble High court of Delhi on 14^th May, 2025 has passed judgement in favour of the assessee, in  the matter of Metalax Industries v.s the Additional commissioner. The Judgement allows the  taxpayers to file a consolidated appeal for multiple financial years if a single SCN is issued for multiple  FYs but only one FY mentioned in order.

The dispute initiated with issuance of SCN by the respondent-department to the petitioner - Metalax  industries for wrongful availment of Input tax credit (ITC) though issuance of goods-less Invoices  covering the period from FY 2017-18 to 2019-20. The SCN was a result of a search conducted at the  premises and the arrest of proprietor for the same. The SCN was duly replied by the petitioner for the  period under consideration. A common adjudication order in FORM DRC-07 was passed by the  respondent department creating a collective demand of INR 6.35 crores for three financial years while  mentioning only FY 2017-18 in the impugned order.

The Petitioner filed a consolidated appeal u/s 107 however, it was disapproved by additional  commissioner and directed the petitioner to file separate appeals for each financial year under  consideration.

The petitioner contended that filling of separate appeals for a common adjudication order is burdensome  and unnecessary. Considering the petitioner’s argument, the court allowed for filing of consolidated  appeal on fulfillment of pre-deposit u/s  section 107 CGST Act, 2017.