Composite GST assessment orders covering multiple financial years are unsustainable where separate tax periods require separate proceedings.

A single composite GST assessment order covering more than one financial year was found unsustainable because the GST framework contemplates separate treatment for distinct tax periods. The court applied the view that a single show-cause notice or composite assessment order cannot validly span multiple assessment years where separate proceedings are required. On that basis, the order was set aside and liberty was given to initiate separate proceedings for each assessment year, while the remaining grounds were not adjudicated.

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

Analysis: The assessment order covered multiple financial years. The governing view applied was that a single show-cause notice or a single composite assessment order cannot be issued for more than one tax period in the manner contemplated under the GST framework. Since the petitioner pressed this ground as the primary challenge, the writ petition was disposed of on that basis, without adjudicating the remaining grounds.

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

Ratio Decidendi: A single show-cause notice or composite assessment order cannot validly cover multiple tax periods or financial years where separate assessment treatment is required under the GST regime.

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