Composite GST notices and assessments covering multiple tax periods are impermissible; fresh year-wise proceedings may be initiated.

Under the GST framework, a composite show-cause notice and a composite assessment order covering multiple tax periods were held unsustainable where period-wise adjudication is required. The Court followed the existing Division Bench view that proceedings cannot be issued as a single notice or single order for more than one financial year in the manner adopted here. The impugned notice and assessment order were set aside, and fresh proceedings were permitted to be initiated separately for each assessment year. Other grounds were left open.

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Issues: Whether a single show-cause notice and a single assessment order covering more than one financial year under the GST regime are legally sustainable, and whether such proceedings must be initiated separately for each assessment year.

Analysis: The Court noted that the petitioner challenged a composite show-cause notice and assessment order covering the period from April 2018 to March 2023. It relied on the view already taken by a Division Bench that a single show-cause notice or a single composite assessment order cannot be issued in relation to more than one tax period in the manner indicated. Since the petitioner pressed only this principal ground, the Court disposed of the writ petition on that basis and left the other grounds open.

Conclusion: A single composite show-cause notice and a single composite assessment order covering multiple assessment years were held impermissible, and the impugned notice and assessment order were set aside with liberty to initiate fresh proceedings separately for each assessment year.

Final Conclusion: The challenge succeeded on the ground of impermissible composite proceedings, resulting in quashing of the impugned action and permitting fresh year-wise proceedings.

Ratio Decidendi: Under the GST framework, a composite notice or assessment covering more than one tax period cannot be sustained where the statute requires period-wise adjudication and separate proceedings for each assessment year.

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