In a recent ruling, the Andhra Pradesh High Court held that a single Goods and Services Tax (GST) show cause notice or a composite assessment order is impermissible for multiple tax periods.
Venkata Naga Sai Stone Crushers, represented by its Managing Partner Matta Srinivasa Rao, submitted a writ petition before the Andhra Pradesh High Court contesting the adjudication order dated 29 December 2025 passed by the Assistant Commissioner, Peddapuram Circle. The order was passed under Section 73 of the GST Act, 2017, and covered the financial years 2021-22 to 2023-24.
The applicant said that its business had stopped and its GST registration had been cancelled w.e.f 31 January 2021. It contested the measure of fastening the GST obligation on it for the financial years 2021-22 to 2023-24, claiming that it was not lawful, arbitrary, and without jurisdiction.
However, the applicant raised numerous grounds; its main claim before the Court was that a single assessment order for more than one fiscal year breached Sections 73 and 74 of the GST Act, 2017. As per the applicant, the impugned order was composite and was obligated to be set aside on that mere ground.
The Government Pleader for Commercial Taxes represented the respondents. The order does not record any detailed separate argument from the respondents on the matter.
The Division Bench, including Justice R. Raghunandan Rao and Justice T.C.D. Sekhar stated that the applicant had been given an order on 29 December 2025 and that the said assessment order covered the tax period from 2021-22 to 2023-24.
The Court mentioned that the applicant had outlined the ground that one assessment order could not include more than one fiscal year. It referred to the earlier Division Bench decision in W.P. No. 11028 of 2025 and batch, where the Court had already stated that a single show-cause notice or single composite assessment order cannot be passed for more than one tax period in the manner mentioned above.
“A single show-cause notice or a single composite assessment order cannot be passed in relation to more than one tax period of 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 the annual return has been reached.”
The applicant cited merely the main ground concerning the composite order, so the court disposed of the writ petition on that problem and left the other grounds open. The Court quashed the impugned order on 29 December 2025. It furnishes a chance to the respondents to start fresh proceedings for each assessment year.
Also Read: AP HC Unsigned GST Assessment Order Held Legally Defective Can’t Be Sustained in Law
The court directed that the period from the date of passing of the impugned order till the date of receipt of the High Court’s order shall be excluded for limitation. No order as to costs was made, and pending miscellaneous applications, if any, were closed.
| Case Title | Venkata Naga Sai Stone Crushers Vs Assistant Commissioner |
| Case No. | Writ Petition No: 16671/2026 |
| For Petitioner | Karthik Ramana Puttamreddy |
| For Respondent | GP for Commercial Tax GP for Mines and Geology |
| Andhra Pradesh High Court | Read Order |
