1. Delay condoned
2. However, we find no good ground and reason to interfere with the
impugned judgment/order passed by the High Court [2025-VIL-
909-DEL].
3. The special leave petition is, accordingly, dismissed.
4. Pending application(s), if any, shall stand disposed of.
(emphasis supplied)
4. On the backdrop of the above decisions rendered by the various High
Courts and Co-ordinate benches of this Court, it is clear that there is a cleavage of
opinion on the issue, whether a consolidated show-cause notice for multiple
financial years, could be issued by the Department.
5. When the present batch of Petitions were taken up for hearing, the
Petitioners on one hand argued that these Petitions need to be allowed following
the decision of the co-ordinate Bench in Milroc (supra), whereas on the other
hand, on behalf of the Revenue, it was urged that considering the orders passed by
the Supreme Court dismissing Special Leave Petitions in the case of Mathur
Polymers (supra) being law of the land under Article 141 of the Constitution, as
also considering the order passed by the Supreme Court in Ambika Traders
(supra), the issue requires a re-consideration, including to examine whether the
decision in Milroc (supra) lays down the correct position in law.