The petitioner challenged a show cause notice issued under Section 73 covering multiple financial years in a single proceeding. The factual background showed that the notice clubbed tax periods from 2019-20 to 2023-24 without issuing separate notices for each year.
The Court held that Section 73 contemplates independent proceedings for each tax period and clubbing of multiple years in a single notice is impermissible. The impugned notice and summary were held to be without jurisdiction and were quashed.