JPR Projects Vs State of Andhra Pradesh (Andhra Pradesh High Court)
Deemed Withdrawal of Best Judgment Assessment on Filing Returns under Section 62(2) of CGST Act, 2017
Deemed Withdrawal of Best Judgment Assessment on Filing Returns under Section 62(2), Recovery or adjustment based on a withdrawn order is illegal and must be reversed: Andhra Pradesh High Court
Deemed Withdrawal of Best Judgment Assessment on Filing Returns under Section 62(2), Recovery or adjustment based on a withdrawn order is illegal and must be reversed: Andhra Pradesh High Court
The Andhra Pradesh High Court’s Landmark Ruling: A Deemed Withdrawal of Best Judgment Assessment
A recent judgment by the Andhra Pradesh High Court has provided significant relief and clarity for taxpayers under the Goods and Services Tax (GST) regime. The case of JPR Projects Versus The State Of Andhra Pradesh dated August 20, 2025, addresses a critical issue: the validity of a “best judgment assessment” order once a taxpayer files their pending returns. The court’s decision reinforces the statutory provisions of Section 62(2) of the CGST/APGST Act, affirming that the withdrawal of such an order is automatic and does not require explicit confirmation from tax authorities.
Facts of the Case
The case centered on a registered GST dealer who failed to file their returns for a specific period. In response, the tax authorities, using their power under Section 62(1) of the CGST/APGST Act, issued a best judgment assessment order on February 7, 2024, demanding tax from the dealer.
