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

A single composite GST assessment order cannot cover more than one tax period, and the permissible unit of assessment depends on whether the annual return due date has been reached. Applying its prior Division Bench view, the HC held that a single show-cause notice or composite assessment order for multiple financial years is not sustainable under the GST framework. The impugned assessment and appellate orders were set aside, and the revenue was left free to initiate fresh proceedings separately for each assessment year.

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Issues: Whether a single composite assessment order covering more than one tax period was legally sustainable under the GST framework.

Analysis: The Court noted that the petitioner challenged the assessment and appellate orders on the ground that a composite order had been passed for more than one financial year. Relying on the prior Division Bench view, it held 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 the permissible unit of assessment depends on whether the annual return due date has been reached.

Conclusion: The impugned assessment and appellate orders were set aside, and the respondents were left free to initiate fresh proceedings separately for each assessment year.

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