Kerala High Court Quashes Composite GST Notices Issued to Actor Honey Rose

The Kerala High Court on Monday refused to set aside composite GST show cause notices and assessment orders issued to actor Honey Rose Varghese and several other taxpayers, holding that it was bound by earlier Division Bench rulings requiring separate proceedings for each assessment year.

Allowing the batch of petitions, Justice Ziyad Rahman A.A. observed that there was no stay on the earlier orders of the court and was therefore bound by it. “In this case, evidently, no stay is also obtained against the judgment in Lakshmi Mobile (supra) or Tharayil Medicals (supra). Therefore, I am bound to follow the observations and principles laid down by the Division Bench of this Court in the aforesaid decisions."

The judgment, delivered on February 16, 2026, disposed of a large cluster of writ petitions challenging “composite show cause notices” and “composite assessment orders” issued under the GST regime. In several cases, a single notice covered multiple financial years, in some instances up to six years in one proceeding.

Honey Rose's petition formed part of this batch. The petitioners contended that the GST department could not club together multiple assessment years in one notice or order. They relied on earlier Division Bench decisions of the Kerala High Court which had held that separate proceedings are required for each assessment year.

The State relied on a contrary view taken by the Delhi High Court, which had observed that there was no prohibition in the statute against issuance of a composite notice for multiple assessment years. The State further argued that since the Supreme Court of India had dismissed Special Leave Petitions against the Delhi High Court decisions, the Kerala High Court was no longer bound by its own earlier Division Bench rulings.

Rejecting this contention, Justice Rahman clarified that dismissal of an SLP in limine does not amount to a declaration of law under Article 141 of the Constitution.

The Court held, "On going through the orders passed in the SLP, it can be seen that no detailed discussion with regard to the merits of the findings or the questions of law are made by the Honourable Supreme Court and hence, I am of the view that the fact that the view taken by the Delhi High Court was not interfered with by the Honourable Supreme Court by dismissing the SLP, by itself cannot be a ground to take a different view in this case, than the one taken by the Division Bench of this Court in Lakshmi Mobile (surpa) and Tharayil Medicals (surpa)."

Holding itself bound by its earlier Division Bench rulings, the court quashed the impugned composite notices and orders issued to the actor and other petitioners. However, it granted liberty to the assessing officers to issue fresh notices separately for each relevant assessment year and proceed in accordance with law.