A single show-cause notice or composite GST assessment cannot validly cover more than one tax period; where assessment is taken before the annual return due date, the bar applies beyond one month, and after that due date, beyond one year. The assessment and appellate orders were set aside because the challenge was confined to the impermissible clubbing of multiple assessment years. Authorities were left free to start fresh proceedings separately for each assessment year, and the intervening period was directed to be excluded while computing limitation.
A single show-cause notice or composite GST assessment cannot validly cover more than one tax period; where assessment is taken before the annual return due date, the bar applies beyond one month, and after that due date, beyond one year. The assessment and appellate orders were set aside because the challenge was confined to the impermissible clubbing of multiple assessment years. Authorities were left free to start fresh proceedings separately for each assessment year, and the intervening period was directed to be excluded while computing limitation.
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