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Single Composite GST Assessment Order for Mutiple Years Invalid: AP HC

Case Law Details

TaxGuru Citation
2026 taxguru.in 5937
Case Name
Srivalli Shipping Andtransport Private Limited Vs Additional Commissioner of Central Tax (Andhra Pradesh High Court)
Date of Judgement/Order
Only available for paid members
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Srivalli Shipping Andtransport Private Limited Vs Additional Commissioner of Central Tax (Andhra Pradesh High Court)

The Andhra Pradesh High Court set aside a GST assessment order dated 29.12.2025 issued against the petitioner company because the order covered two financial years, namely 2018-19 and 2019-20, through a single composite assessment. The petitioner contended that passing one assessment order for multiple financial years violated Sections 73 and 74 of the GST Act, 2017.

The Court referred to an earlier Division Bench judgment in W.P. No.11028 of 2025 and batch, which held that a single show-cause notice or composite assessment order cannot be issued for more than one tax period or more than one financial year once the due date for filing the annual return has been reached.

Although the petitioner had raised several grounds challenging the assessment, the Court considered only the issue relating to the composite order. On that basis, the writ petition was disposed of by setting aside the impugned assessment order while leaving open the other grounds of challenge.

The Court also granted liberty to the respondents to initiate fresh proceedings separately for each assessment year. It further directed that the period between the passing of the impugned order and receipt of the present order would be excluded for limitation purposes. No order as to costs was passed.

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Author Info

CA Sandeep Kanoi
Qualification: CA in Job / Business
Company: Taxguru Consultancy
Location: Mumbai, Maharashtra
Articles Published: 19,235

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