Composite GST show cause notice and assessment order invalid where they covered multiple tax periods.

Under the GST enactments, notices and assessments under Sections 73 and 74 must relate to a specific tax period, and a composite proceeding covering multiple assessment years is not sustainable in law. Applying the binding interpretation already accepted by the parties, the Andhra Pradesh HC held that a single composite show cause notice and a single composite assessment order could not validly cover different assessment years. Because the impugned proceedings were issued as composite actions for multiple years, both the notice and the assessment order were invalid, and the petitioner succeeded.

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Issues: Whether a single composite show cause notice and a single composite assessment order could validly cover multiple assessment years or tax periods under the GST enactments.

Analysis: The Court followed the binding interpretation that the expressions used in Sections 73 and 74 contemplate notices and assessments with reference to a tax period, and that a composite proceeding covering more than one assessment year is unsustainable. The challenged proceedings related to multiple years, and the respondents did not dispute that the issue was covered by the earlier Division Bench ruling. Since the impugned notice and assessment order were issued as composite proceedings for different assessment years, they could not be sustained in law.

Conclusion: The composite notice and composite assessment order were held invalid, and the petitioner succeeded.

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