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IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI
R.RAGHUNANDAN RAO, T.C.D.SEKHAR
S.J. Constructions – Appellant
Versus
Assistant Commissioner – Respondent
JUDGMENT :
R. RAGHUNANDAN RAO, J.
1. As a common issue has been raised in all these writ petitions, they are being disposed of by way of this common order.
2. Heard Sri M.V.J.K. Kumar, learned counsel appearing for the petitioner in all the writ petitions and learned Government Pleader for Commercial Tax appearing for the respondents in all the writ petitions.
3. In all these cases, the petitioners, who are registered persons under the GST regime, are challenging the orders of assessment, on the grounds of lack of signature and lack of DIN number. Apart from this, the petitioners also challenge the impugned orders on the ground that different assessment years have been bunched together and a composite show cause notice and a composite order had been issued in relation to different tax periods, and the same is impermissible and not in accordance with the provisions of the APGST Act, 2017.
4. The details of the assessment years for which the impugned orders have been passed are set out below:
| W.P. No. | Assessment years | Assessment order date | Appeal order date |
| W.P.No.11028/2025 | April 2018 to March 2022 | 21.07.2023 | Nil |
| W.P.No.11206/2025 | July 2017-2018 2018-2019 April 2019 Oct 2022 | 03.05.2023 | Nil |
| W.P.No.176 | |||
The court held that composite assessment orders for multiple financial years violate statutory provisions, emphasizing that each period must have a separate assessment to protect registered persons' ....
Composite show-cause notices covering multiple financial years under CGST/KGST Act are illegal as assessments must pertain to individual years, respecting statutory limitations and ensuring natural j....
Composite notices under the CGST/SGST Act for multiple assessment years are unsustainable; individual notices must be issued to uphold fairness for taxpayers.
Multiple Show Cause Notices can exist for the same tax period under GST if they pertain to different subjects, reinforcing the absence of a bar under the GST regulations.
Natural justice is upheld when multiple opportunities to be heard are provided; consolidated orders across tax periods are permissible under CGST law without causing prejudice unless demonstrable har....
Tax authorities must issue separate show cause notices for each financial year under Section 74 of the CGST Act to ensure fairness and compliance with statutory timelines.
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