Mathur Polymers Vs Union of India & Ors

Date: November 7, 2025

Court: Supreme Court
Type: Special Leave Petition
Judge(s)/Member(s): SANJAY KUMAR, ALOK ARADHE

Subject Matter

Fraudulent availment of ITC: Consolidated SCN and order for multiple financial years is permissible and tenable. HC Ruling upheld.

Service Of NoticeShow Cause NoticeAdjudication

Summary

The Supreme Court of India dismissed a Special Leave Petition (SLP) filed by Mathur Polymers, upholding the Delhi High Court's judgment on the validity of an assessment order confirming a tax demand (₹81.54 lakh) for alleged fraudulent Input Tax Credit (ITC). The petitioner had challenged the order primarily on two procedural grounds: violation of natural justice (non-receipt of hearing notices) and illegal "bunching" of multiple financial years into a single order.

The Delhi High Court, whose decision was affirmed, had found that:

  1. Valid Service: Hearing notices were adequately served via email to the petitioner's registered email address (Section 169(1)(c) of the CGST Act).

  2. Valid Consolidated Order: The consolidation of multiple years into one notice/order was permissible under Sections 73 and 74 of the CGST Act, as the legislative intent allows for the use of "period" instead of "financial year" to investigate complex, multi-year fraud patterns.

The Supreme Court dismissed the Special Leave Petition, finding "no good ground and reason to interfere" with the impugned judgment of the High Court.

Delay condoned.

However, we find no good ground and reason to interfere with the impugned judgment/order passed by the High Court.

The special leave petition is, accordingly, dismissed.

Pending application(s), if any, shall stand disposed of.