Single GST Assessment Order for Multiple Tax Periods Held Invalid: Andhra Pradesh High Court

Case Overview

The Andhra Pradesh High Court, in G M R A Shaha Iron Steels Vs Assistant Commissioner State Tax, has ruled that a composite GST assessment order spanning more than one financial year is legally impermissible. The Court set aside an assessment order that clubbed two distinct tax periods — 2020-21 and 2023-24 — into a single order, reaffirming the principle that each assessment year must be addressed through a separate, independent proceeding.

Background and Facts of the Case

The petitioner, a registered firm carrying GSTIN No.37ERGPK1190A1Z2, was aggrieved by an assessment order dated 27.05.2025 issued by the first respondent — the Assistant Commissioner, State Tax. The singular and most prominent objection raised before the High Court was that the impugned order was composite in character, covering two non-consecutive tax periods, namely 2020-21 and 2023-24, within a single assessment order.

The petitioner had raised several additional grounds of challenge in the writ petition. However, before the Andhra Pradesh High Court, the petitioner chose to press only the primary ground — the composite nature of the assessment order. The Court, therefore, confined its adjudication strictly to this ground and deliberately left all remaining grounds open for future consideration if fresh proceedings were to be initiated.

Key Issue: Whether a single composite GST assessment order covering more than one financial year is legally sustainable under the provisions of the Central Goods and Services Tax Act.

Legal Framework: Sections 73 and 74 of the CGST Act

The foundation of the petitioner's challenge rested on the interpretation of Section 73 and Section 74 of the Central Goods and Services Tax Act, read alongside corresponding provisions of the Andhra Pradesh GST Act.

The Argument on Composite Orders

The petitioner's learned counsel, Mr. P.V. Sai Rajesh, drew the Court's attention to specific averments in the supporting affidavit and contended that passing a consolidated assessment order for multiple tax periods in one go is fundamentally contrary to the scheme of the CGST Act. The statutory design, it was submitted, contemplates separate proceedings for each distinct tax period.

Reliance on a Co-ordinate Bench Decision

The petitioner placed primary reliance on the ruling of a Co-ordinate Bench of the same Court in S.J. Constructions v. The Assistant Commissioner & Others (W.P. No.11028 of 2025 & batch), dated 17.09.2025, which directly addressed the very question of whether composite show cause notices or composite assessment orders can cover more than one tax period or financial year.

The Co-ordinate Bench in S.J. Constructions held as follows: