Composite GST assessment orders cannot cover multiple tax periods where separate proceedings are required for each assessment year.

Under GST law, a single show-cause notice or composite assessment order should not cover more than one tax period where separate assessment proceedings are required for each assessment year after the annual return due date. The composite order challenged on that basis was treated as unsustainable and set aside, with liberty to initiate fresh proceedings separately for each assessment year.

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Issues: Whether a single composite assessment order covering more than one tax period was sustainable under the Goods and Services Tax law.

Analysis: The order was challenged on the ground that a single assessment order had been passed for multiple years. The Court relied on the view that a single show-cause notice or a single composite assessment order cannot be issued for more than one tax period, and that separate proceedings are required for each assessment year where the annual return due date has been reached.

Conclusion: The composite assessment order was not sustainable and was set aside, along with the appellate order, with liberty to initiate fresh proceedings separately for each assessment year.

Ratio Decidendi: A single show-cause notice or composite assessment order cannot validly cover multiple tax periods where separate assessment proceedings are required for each tax period or assessment year.

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