Multi-Year SCNs - The Legislative Response to the Bunching Controversy

The proposed validation clause represents a legislative response to judicial decisions questioning the validity of GST show cause notices clubbing multiple financial years. While the objective appears to be protecting Revenue proceedings from procedural challenges, the scope and constitutional validity of the eventual amendment will depend on its precise drafting. The critical distinction is between curing a statutory defect and retrospectively reversing the consequences of judicial decisions, especially in cases where notices have already been quashed or the proceedings have attained finality.