Composite GST assessment orders covering multiple tax periods are unsustainable; separate year-wise proceedings are required.

Under the GST framework, a single show-cause notice or composite assessment order cannot validly cover more than one tax period where separate year-wise adjudication is required. Applying that principle, the multi-year assessment order was found unsustainable and was set aside. Liberty was reserved for the revenue to initiate fresh proceedings separately for each assessment year, and the petitioner's relief was subject to the stipulated deposit condition. 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 sustainable, and whether such order can be set aside with liberty to initiate year-wise proceedings.

Analysis: The challenge was confined to the legality of a single assessment order covering multiple financial years. The order recorded that the point was already answered by a Division Bench, which held that a single show-cause notice or a single composite assessment order cannot be passed in relation to more than one tax period, and that separate proceedings are required once the annual return due date has been reached. The writ petition was therefore disposed of on that principal ground, while the remaining grounds were left open.

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

Final Conclusion: The petitioner obtained relief against the impugned multi-year assessment, subject to the stipulated deposit condition, and the respondents were permitted to proceed afresh in year-wise assessments.

Ratio Decidendi: Under the GST framework, a single assessment or show-cause proceeding cannot validly cover more than one tax period where separate year-wise adjudication is required.

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