Bhaarat Group Private Limited, based in Nagarjuna Nagar, Vijayawada, decided they had had enough and took their fight to the Andhra Pradesh High Court at Amaravati. Leading the charge was Rajasekar, the director and son of Venkata Subba Reddy.
They filed Writ Petition No. 7121 of 2026 because they were fed up with an assessment order dated July 5, 2022. The Assistant Commissioner of State Tax at Benz Circle, No. II Division, Vijayawada, had cut five financial years– 2017-18 through 2021-22 into a single assessment order.
Also Read: Andhra Pradesh HC Quashes ITC Denial, Recognises Extended GST Filing Timeline
GST law does not permit that. The slap demands on them? Rs. 16,71,86,886, divided into Rs. 6,79,78,066 for tax, an equal amount for penalty, including Rs. 3,12,30,754 in interest.
A Division Bench Justice R. Raghunandan Rao and Justice T.C.D. Sekhar heard the case on May 6, 2026. The company was represented by Sri T.V. Suman, and the other side was represented by the Government Pleader for commercial tax.
Bhaarat Group’s claim was explicit: you cannot just bunch up several years and shoot out one big assessment order. Sections 73 and 74 of the GST Act, 2017, have specified the things clearly, and the High Court spelt it out in SJ Constructions (2025 SCC Online 3334). Bhaarat Group has also said that the order blindsided them, furnishing them no chance to explain or defend themselves, which counters natural justice.
They protested the property attachment notice in Form GST DRC-17, issued on January 28, 2026, which had followed from this illegal order.
Writ Petition is disposed of, after hearing both sides, setting aside the impugned order. They leaned on their previous decision in W.P. Nos. 11028 of 2025 and others, and made it clear: you cannot include more than 1 tax period, no matter if it’s monthly or yearly, with a single show-cause notice or assessment order.
Due to this, the Court tossed out the composite assessment order from July 5, 2022, and scrapped all recovery actions, along with the property attachment. Now the GST authorities are required to again do everything, issuing separate proceedings for each year.
However, the Bhaarat Group is not fully free from fault; they are required to deposit 20% of the disputed tax, though any earlier payments count for this. The Bench made sure the time lost in the middle shall not count against them for limitation objectives. No costs were awarded, and all miscellaneous applications were closed.
Important: How GST Software Handles Notices & Hearings Easily U/S 73
The GST authorities are not permitted to break the law. They should follow the rules and give taxpayers a fair chance each year. No more clubbing years together.
| Case Title | M/s. Bhaarat Group Pvt. Ltd. Vs. Assistant Commissioner St |
| Case No. | Writ Petition No: 7121/2026 |
| Counsel For Petitioner | Thanjavuru Venkata Suman |
| Counsel For Respondent | GP for Commercial Tax |
| Andhra Pradesh High Court | Read Order |
