consolidated orders for fy 2019 -20, 2020-21 issued

[giri gattupalli]

respected sir, consolidated order in FORM DRC-07 issued on my client for FY 2019-20. 2020-21 in sep 2022. issue is still pending with ADC. in recent times high courts are strucking down composit orders.  as the limitation period  for FY 19-20, 2020-21 is crossed, is there any chance to get re assed for FY 2019-20, and 2020-21, if high court struck down the composite order.

thanking you

[Shilpi Jain]

Limitation period applies for issuance of the show cause notice. The time limit in the law of 1 year given for passing of orders is not mandatory but more recommendatory.

So on limitation you cannot contest (Assuming SCN is issue in time). However, you can consider approaching courts for challenging composite SCN and order by consulting a professional in this regard as the analysis will differ based on facts of each case.

[Sadanand Bulbule]

There are judgements which support and oppose such composite SCNs. There is no harm in taking a chance as indicated by madam.

[VENU K]

High Courts may strike down composite orders due to procedural infirmities, it is highly probable that the matter would be remanded for fresh adjudication. In such a scenario, Section 75(3) of the CGST Act, 2017 would provide a fresh two-year period for the department to issue separate orders for FY 2019-20 and 2020-21, allowing for reassessment. Therefore, there is a significant chance of reassessment for these financial years if the High Court strikes down the composite order and remands the case.

[KASTURI SETHI]

                        In case Section 74 has been invoked in the SCNs,  it is worthwhile to peruse the following case laws which are  in                                    favour  of the department :-

                          (i) (2026) 38 Centax 135 (S.C.) [07-11-2025]

                         (ii) (2025) 35 Centax.150 (Delhi High Court) (26.08.25)

                              Mathur Polymers  Vs. UOI

AI Summary

Composite GST assessment orders and reassessment prospects if High Court strikes them down and remands for fresh adjudication. Composite GST assessment orders issued in one FORM DRC-07 for multiple fiscal years can be struck down for procedural infirmity, which typically leads to remand for fresh adjudication; if remanded, the department may obtain a new limitation window for reassessment under the statutory provision permitting a fresh period to pass separate orders, so reassessment for FY 2019-20 and 2020-21 becomes possible. The limitation analysis distinguishes time for issuing show cause notices (which remains critical) from the time for passing orders (treated as recommendatory in some views). Departmental reliance on extended assessment provisions and favourable case law supports reassessment where procedural defects require reissuance of separate orders.