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Issues: Whether a single composite order of assessment covering more than one financial year under the GST regime is valid and, if not, whether the impugned order should be set aside with liberty to proceed separately for each assessment year.
Analysis: The challenge was confined to the legality of a composite assessment order covering multiple financial years. Reliance was placed on the settled view that a single show-cause notice or composite assessment order cannot be issued for more than one tax period where the statute contemplates assessment period-wise treatment. On that basis, the impugned order was found unsustainable as it covered several assessment years in one proceeding.
Conclusion: The composite assessment order was held invalid and was set aside, with liberty to the respondents to initiate fresh proceedings separately for each assessment year.