Composite assessment orders for multiple financial years are unsustainable; separate proceedings must be initiated for each assessment year.

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....A single show-cause notice or composite assessment order cannot validly cover more than one tax period once the due date for filing the annual return has been reached. Applying an earlier Division Bench view, the HC held that the impugned assessment, framed by one order for multiple financial years, was unsustainable and set it aside. The matter was remitted with liberty to commence fresh proceedings separately for each assessment year, and the intervening period was excluded for limitation purposes. All other grounds raised by the petitioner were left open.....