Andhra Pradesh High Court Strikes Down Composite GST Assessment Covering Multiple Tax Periods — P. Venkataramaniah Vs Assistant Commissioner ST
Case Overview
| Particulars | Details |
|---|---|
| Case Name | P. Venkataramaniah Vs Assistant Commissioner ST |
| Court | Andhra Pradesh High Court |
| Writ Petition No. | 2136 of 2025 |
| Date of Order | 08/07/2026 |
Background and Facts of the Case
A partnership firm operating in the work contract services sector, rendering services to various State Government departments, was a registered GST assessee holding GSTIN No. 37AACFP7143H1Z6 under the jurisdiction of the first respondent. The assessee approached the Andhra Pradesh High Court by way of a writ petition, assailing an assessment order dated 31.08.2024 that had been passed by the fourth respondent.
The core grievance of the assessee was that the impugned assessment order clubbed together multiple tax periods — spanning from 2018-2019 through 2021-2022 — into a single composite order. The assessee argued that such an approach of passing one consolidated order for several distinct tax periods was fundamentally impermissible under the legislative framework of the Central Goods and Services Tax Act.
The Legal Challenge: Why Composite Orders Are Impermissible
The Foundational Argument
The counsel for the assessee drew the Court's attention to the legal infirmity underlying the issuance of a single assessment order covering more than one tax period. The argument was rooted in a reading of the relevant provisions of the Central Goods and Services Tax Act, particularly Section 73 and Section 74, which deal with the determination of tax not paid, short paid, erroneously refunded, or input tax credit wrongly availed.
The contention was that each tax period stands as an independent unit of assessment under the GST framework, and therefore, the revenue authorities are obligated to issue separate show cause notices and pass separate orders for each such period.
Reliance on Coordinate Bench Ruling
The assessee placed significant reliance on the decision rendered by a coordinate bench of the same High Court in S.J. Constructions v. The Assistant Commissioner & Others (W.P No. 11028 of 2025 & batch), dated 17.09.2025. The relevant extract from that judgment, which was pressed into service before the Court, reads as follows: