Invalidity of Composite GST Assessment Orders Spanning Multiple Financial Years

The Andhra Pradesh High Court has delivered a pivotal judgment concerning the procedural validity of assessment orders under the Goods & Services Tax Act, 2017. In the matter of Shirdi Sai Enterprises Vs Deputy Assistant Commissioner of State Tax, the Court addressed whether tax authorities are permitted to issue a single, composite assessment order covering multiple financial years.

The High Court firmly held that such composite orders are impermissible, reinforcing the principle that assessments must be conducted independently for each tax period.

Factual Matrix

The petitioner, Shirdi Sai Enterprises (hereinafter referred to as the "assessee"), was a registered entity under the Goods & Services Tax Act, 2017. The factual timeline presented to the Court indicated that the assessee’s GST registration was cancelled on 23.02.2021, with retrospective effect from 08.02.2021. Following this cancellation, the assessee ceased all business operations.

The dispute arose when the Revenue authorities issued an assessment order dated 07.07.2023. This single order purported to assess the tax liability of the assessee for three distinct periods:

• 2018–19
• 2019–20
• 2020–21

The assessee challenged this order via a Writ Petition, contending that grouping multiple assessment years into one document violates established legal procedures.