Composite GST assessment order for multiple periods invalid separate orders required for each year { A Square Associates vs. Deputy Assistant Commissioner Sti [2026] 186 taxmann.com 204 (Andhra Pradesh)}
Facts
- Petitioner challenged a GST assessment order passed by the department.
- The impugned order covered more than one financial year/tax period through a single consolidated assessment proceeding.
- Petitioner contended that under Sections 73/74 of the CGST/APGST Act, assessment proceedings must be conducted separately for each tax period or assessment year.
- Reliance was placed on earlier Andhra Pradesh High Court rulings holding that composite show cause notices or assessment orders for multiple years are impermissible.
Issue
Whether a single composite GST assessment order covering multiple tax periods/financial years is valid in law
Held
The Andhra Pradesh High Court held that:
- A composite assessment order covering multiple financial years/tax periods is not sustainable under the GST law.
- Separate proceedings and separate assessment orders are required for each assessment year/tax period.
- Since the impugned order clubbed several periods together, it was liable to be set aside.
The Court granted liberty to the department to initiate fresh proceedings separately for each relevant assessment year in accordance with law
