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Issues: Whether a single composite assessment order covering more than one assessment year was legally sustainable under the GST framework, and whether the assessment had to be set aside with liberty to initiate separate proceedings year-wise.
Analysis: The challenge was confined to the legality of passing one assessment order for multiple financial years. The Court followed the previously decided view that a single show-cause notice or composite assessment order cannot be issued in relation to more than one tax period in the manner contemplated by the GST provisions. Since the petitioner pressed only this primary ground, the Court did not adjudicate the remaining grounds and disposed of the writ petition on this basis.
Conclusion: The composite assessment order was unsustainable and was set aside. The matter was remanded with liberty to the respondents to commence fresh proceedings separately for each assessment year, and the period specified by the Court was excluded for limitation purposes.
Final Conclusion: The petitioner succeeded on the challenge to the composite nature of the assessment, while the Department was permitted to proceed afresh year-wise.
Ratio Decidendi: A composite assessment or show-cause proceeding covering multiple tax periods is impermissible where the statutory scheme requires period-specific proceedings, and such an order is liable to be set aside with remand for separate year-wise action.