The Andhra Pradesh High Court, in a ruling, has mentioned that a common or composite GST assessment order that includes more than one tax period cannot be sustained.
The assessment order has been contested by a registered firm, which was passed u/s 74 of the GST Act in a consolidated manner for tax periods including financial years 2020-21 to 2023-24.
The counsel of the taxpayer, G M R A Shaha Iron Steels, has claimed that passing one assessment order for multiple tax periods was not allowable under the Central Goods and Services Tax Act.
They placed reliance on the Andhra Pradesh High Court’s earlier decision in S.J. Constructions v. Assistant Commissioner & Others where it stated that “a single show cause notice or a single composite assessment order cannot be passed in relation to more than one tax period of either a month if the assessment is taken up before the due date for filing of the annual return or for more than one year if the due date for filing of annual return has been reached.”
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The counsel for the revenue did not specify any objection in the case.
The Division Bench, Justice Ninala Jayasurya and Justice T.C.D. Sekhar quashed the assessment order and allowed the GST authorities to start fresh proceedings separately for each assessment year.
“Accordingly, this writ petition is disposed of, setting aside the impugned assessment order dated 27.05.2025, leaving it open to the respondents to initiate fresh proceedings, for each assessment year separately.”
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The relief was given on the condition that the applicant must deposit 20% of the disputed tax within 6 weeks from the receipt of the order. The amount paid after the assessment order was passed shall be adjusted while computing the 20% deposit.
| Case Title | M/s. G M R A Shaha Iron Steels vs. The Assistant Commissioner, State Tax |
| Case No. | WRIT PETITION NO: 22817 OF 2026 |
| For Petitioner | P VASU Sekhar |
| For Respondent | GP for Commercial Tax |
| Andhra Pradesh High Court | Read Order |
