Composite GST assessment orders for multiple tax periods are invalid; separate proceedings are required for each assessment year.

A single composite GST assessment order covering more than one distinct tax period was held invalid because assessment under the GST framework must be made separately for each tax period. The Court treated the impugned order, which spanned several financial years, as unsustainable on that ground and set it aside. Other challenges were not adjudicated and were left open. Liberty was granted to initiate fresh proceedings separately for each assessment year.

---

---

Issues: Whether a single composite assessment order covering more than one financial year under the GST regime is valid.

Analysis: The challenge was confined to the legality of passing one assessment order for multiple tax periods. The governing principle applied was that where assessment is undertaken for distinct tax periods, a single show-cause notice or composite assessment order cannot validly cover more than one tax period in the manner proscribed by the GST framework. Since the impugned order covered an extended period spanning several financial years, it was treated as unsustainable on this ground. Other grounds were not adjudicated and were left open.

Conclusion: The composite assessment order was held invalid and was set aside, with liberty to initiate fresh proceedings separately for each assessment year.

Ratio Decidendi: Under the GST assessment scheme, a single composite assessment order cannot validly determine liability for more than one distinct tax period in the manner found impermissible by the Court.

---