Andhra Pradesh High Court Invalidates Single GST Assessment Order Covering Multiple Financial Years

Background of the Dispute

The case titled Venkata Naga Sai Stone Crushers Vs Assistant Commissioner reached the Andhra Pradesh High Court challenging an assessment order issued under the GST regime. The assessee, a registered company engaged in business and registered under the GST laws, questioned the legality of an order dated 29.12.2025 passed by the 1st respondent.

This impugned assessment order dealt with GST liability for multiple financial years, specifically from 2021-2022 to 2023-2024, in a single composite order. The assessee approached the High Court by way of writ petition, primarily contending that such a consolidated assessment order, clubbing more than one financial year, was contrary to the statutory scheme under the GST Act, 2017, particularly Section 73 and Section 74.

Challenge to Composite Assessment Order

The assessee initially put forward several grounds assailing the assessment proceedings and the resultant order. However, during hearing, the assessee chose to focus and press mainly one fundamental contention:

  • A single assessment order encompassing more than one financial year is impermissible under the framework of Section 73 and Section 74 of the GST Act, 2017.

It was thus argued that the assessment order dated 29.12.2025, being composite and spanning multiple years, must be struck down as being in violation of the statutory provisions governing adjudication and determination of tax, interest and penalty.

Reference to Earlier Division Bench Judgment

Binding Precedent Relied Upon

While examining this contention, the High Court referred to an earlier decision rendered by a Division Bench of the same Court in W.P. No.11028 of 2025 & batch. In that batch of writ petitions, the Court had already addressed an identical legal question and given a clear finding on the validity of composite proceedings under GST.

The Division Bench had categorically held that:

A single show-cause notice or a single composite assessment order cannot be issued covering more than one tax period,

  • Whether it relates to more than one month, if assessment is undertaken prior to the due date for filing the annual return; or
  • Whether it relates to more than one year, once the due date for filing of the annual return has already arrived.

This ruling established that tax authorities are required to segregate tax periods and cannot club multiple months or multiple financial years into a single show cause notice or composite assessment order under the mechanisms provided in Section 73 and Section 74.

Application of the Precedent to the Present Case

Court’s Approach to the Assessee’s Limited Challenge