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

A single composite GST assessment order covering more than one financial year is impermissible where separate tax periods require separate proceedings. The Court applied the settled principle that a single show-cause notice or composite assessment order cannot validly relate to multiple assessment years or tax periods. On that basis, the composite assessment order was held unsustainable and set aside, while the respondents were left free to commence fresh proceedings separately for each relevant assessment year.

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Issues: Whether a single composite assessment order covering more than one financial year could be sustained under the GST regime.

Analysis: The assessment order covered multiple financial years. The challenge pressed before the Court was that a single order for more than one tax period was impermissible. The Court followed the settled view that a single show-cause notice or a single composite assessment order cannot be issued in relation to more than one tax period, and that separate proceedings are required for each relevant assessment year or tax period, as applicable.

Conclusion: The composite assessment order was not sustainable and was set aside, with liberty to the respondents to initiate fresh proceedings separately for each assessment year.

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