Madeena Steels Vs Assistant Commissioner of State Taxes (Andhra Pradesh High Court)
The petitioner, a registered company, challenged an assessment order dated 29.11.2022 covering the period from July 2017 to January 2022 and the appellate order dated 23.01.2025 dismissing its appeal. The primary ground pressed was that a single composite assessment order for more than one financial year violated Sections 73 and 74 of the GST Act, 2017.
The Court noted that a Division Bench, in W.P. No. 11028 of 2025 and batch, had already held that a single show-cause notice or a composite assessment order cannot be issued for more than one tax period—either for multiple months where assessment is before the due date for filing the annual return, or for multiple years once the due date has been reached.
Considering this settled position, the Court disposed of the writ petition on the limited ground that the impugned order was a composite assessment. Accordingly, both the assessment order dated 29.11.2022 and the appellate order dated 23.01.2025 were set aside. The respondents were left at liberty to initiate fresh proceedings separately for each assessment year. The period between the impugned order and receipt of the Court’s order was directed to be excluded for limitation purposes. No costs were awarded, and pending applications were closed.
