Composite GST assessment orders spanning multiple financial years are impermissible, and separate proceedings are required for each year.

A composite GST assessment order covering multiple financial years was treated as impermissible because a single assessment or show-cause process cannot validly span more than one tax period in the manner found in the cited precedent. The challenge was confined to that composite structure, and the assessment was therefore set aside. Fresh proceedings may be commenced separately for each assessment year, while the remaining grounds were left open.

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

Analysis: The challenge was confined to the composite nature of the assessment. The order treated a single assessment for multiple financial years as impermissible, and relied on the principle that a single show-cause notice or composite assessment order cannot span more than one tax period in the manner found in the cited precedent. The other grounds were left open.

Conclusion: A single composite assessment order covering multiple financial years was held impermissible, and the impugned assessment was set aside with liberty to commence fresh proceedings separately for each assessment year.

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