Composite Assessment or Show Cause Notices for Multiple Years under the GST Act Are Impermissible


Quick Summary
The Andhra Pradesh High Court has ruled that issuing a single show cause notice or assessment order for multiple tax periods or financial years under the GST Act is not allowed. The court quashed existing composite orders, stating that proceedings must be conducted on a period-by-period basis. This decision aims to protect taxpayers' statutory rights to appeal and avail penalty reliefs, aligning with views from the Madras, Karnataka, and Kerala High Courts.

Court :
Andhra Pradesh High Court

Brief :
The Hon'ble Andhra Pradesh High Court in the case of S J Constructions v. The Assistant Commissioner and Others [W.P. Nos. 11028, 11206, 17671, 20792 of 2025, order dated September 17, 2025] held that a single show cause notice or composite assessment order covering more than one tax period or financial year is impermissible under the GST Act. The Court quashed all such composite assessment and demand orders and clarified that fresh proceedings, if necessary, may only be initiated period-wise, with the limitation period accordingly extended.

Citation :
W.P. Nos. 11028, 11206, 17671, 20792 of 2025, order dated September 17, 2025

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FCA, FCS LLB with21 Yrs of Experience inTaxation Indirect and Direct: Education Qualification: B.Com (Hons) Chartered Accountants Company Secretary LLB Qualified SAP FI/CO Consultants Professional Membership: Chairmanof Indirect Tax Committee of PHD Chamber of Commerce Member of Indirec ... Read more

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