2026:APHC:12670 APHC010087872026 IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI [3529]

(Special Original Jurisdiction)

WEDNESDAY, THE TWENTY FIFTH DAY OF FEBRUARY TWO THOUSAND AND TWENTY SIX PRESENT THE HONOURABLE SRI JUSTICE R RAGHUNANDAN RAO THE HONOURABLE SRI JUSTICE T.C.D.SEKHAR WRIT PETITION NO: 4919/2026 Between:

1. H ARIJANA MAHILA SANKSHEMA SANGHAM, DOOR NO. 7-506, OPPOSITE URDU SCHOOL, SITARAMANJANEYA PETA, MANGALAGIRI, GUNTUR DISTRICT-52250 3, ANDHRA PRADESH, REPRESENTED BY ITS PRESIDENT, SMT. DASARI HEMALATHA, W/O. BALASWAMY, AGED 54 YEARS, R/O. 7-506, SEETHARAMANJANEYAPETA, OPPOSITE URDU SCHOOL, MANGALAGIRI, GUNTUR DISTRICT, ANDHRA PRADESH.

...PETITIONER AND

1. T HE STATE OF ANDHRA PRADESH, REPRESENTED BY ITS PRINCIPAL SECRETARY, FINANCE DEPARTMENT, SECRETARIAT BUILDINGS AT VELAGAPUDI, GUNTUR DISTRICT, ANDHRA PRADESH-522237.

2. T HE ASSISTANT COMMISSIONER STATE TAX, MANGALAGIRI CIRCLE, MANGALAGIRI, GUNTUR DISTRICT, ANDHRA PRADESH-

522503.

3. T HE DEPUTY ASSISTANT COMMISSIONER, MANGALAGIRI CIRCLE, MANGALAGIRI, GUNTUR DISTRICT, ANDHRA PRADESH-

522503.

...RESPONDENT(S):

Petition under Article 226 of the Constitution of India praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased topleased to issue a Writ or Order or Direction more particularly one in the nature of Writ of Mandamus declaring the Assessment Order in Form DRC-07 dated 26.04.2023, (without DIN Number and signature) and the Attachment Notice in Form GST DRC-16 dated 27.01.2026, insofar as they relate to clubbing of financial years 2020- 21 and 2021-22 as illegal, arbitrary and also oppose to Article 14 of the Constitution of India as well as oppose to principles of natural justice as well as the orders dated 17.09.2025 passed in WP No. 11028 of 2025 and batch consequentially stay of all further proceedings pursuant to the impugned notices in Din No. 3727012644172 in Form GST DRC-16 dated 27.01.2026 and orders, including the attachment of properties and to pass IA NO: 1 OF 2026 Petition under Section 151 CPC praying that in the circumstances stated in the affidavit filed in support of the petition, the High Court may be pleased pleased stay of all further proceedings pursuant to the impugned notices in Din No. 3727012644172 in Form GST DRC-16 dated 27.01.2026 and orders, including the attachment of properties pending disposal of the above writ petition and to pass Counsel for the Petitioner:

1. V SAI KUMAR Counsel for the Respondent(S):

1. GP FOR COMMERCIAL TAX

2. GP FOR FINANCE PLANNING The Court made the following Order:

(per Hon’ble Sri Justice R. Raghunandan Rao)

Heard Sri V. Sai Kumar, learned counsel for the petitioner and the learned Government Pleader for Commercial Tax appearing for the respondents.

2. The learned counsel for the petitioner is permitted to amend the prayer in the present Writ Petition, today in the Court itself.

3. The petitioner is a registered Company, which has been served with an order of assessment, dated 26.04.2023, passed by the 2^nd respondent. This order of assessment covers the period from 2020-21 to

2021-22.

4. The petitioner, after having raised various grounds of challenge, has pressed the ground that, a single order of assessment, issued for more than one financial year, would be violative of the provisions of Section 73 and Section 74 of the GST Act, 2017, and consequently, set aside the impugned order of assessment.

5. A Division Bench of this Court, in W.P.No.11028 of 2025 & batch, after considering the said question, had held 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.

6. The petitioner has raised various grounds of challenge. However, the petitioner is pressing the primary ground of the order of assessment being a