M/S. Sri Sai Ganapathi Rice Industries vs. State Of Andhra Pradesh
Held
The High Court, relying on its earlier decision in S J Constructions, held that a single show cause notice or a single composite assessment order cannot be passed for more than one tax period or financial year. The Court found that such composite orders impact the right to appeal and other statutory benefits. Therefore, the impugned common assessment order was set aside.
Facts
The petitioner, a registered GST dealer, challenged a common assessment order issued by the respondent for multiple tax periods spanning 2021-22 to 2024-25. The petitioner contended that such a composite order for several assessment years was unsustainable in law, citing a previous High Court decision.
Key Issues
Whether a single composite assessment order covering multiple tax periods or financial years is legally permissible under the Goods and Services Tax Act.
Sections Cited
Section 73, Section 74, Section 128 of APGST Act
AI-generated summary — verify with the full judgment below
APHC010457982026
IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI (Special Original Jurisdiction) [3543] THURSDAY, THE 3rd DAY OF SEPTEMBER 2026 PRESENT THE HONOURABLE SRI JUSTICE NINALA JAYASURYA THE HONOURABLE SRI JUSTICE T.C.D.SEKHAR WRIT PETITION NO: 24914/2026 Between:
M/S. SRI SAI GANAPATHI RICE INDUSTRIES, GST - 37AEMFS4107G1ZX, REP. BY ITS MANAGING PARTNER, MR. M.SRINIVAS, D.NO.1-4, MAIN ROAD, CHINTHAPALLI-533344, EAST GODAVARI DISTRICT, ANDHRA PRADESH
...PETITIONER AND 1. STATE OF ANDHRA PRADESH, REP BY ITS PRINCIPAL SECRETARY, REVENUE (CT) DEPARTMENT, AP SECRETARIAT, VELAGAPUDI -522503, AMARAVATHI, GUNTUR DISTRICT, A.P
UNION OF INDIA, REP. BY ITS SECRETARY MINISTRY OF FINANCE, 4TH FLOOR, A-WING, SHASTRI BHAVAN, NEW DELHI - 110001. 3. THE DEPUTY ASSISTANT COMMISSIONER STI, PEDDAPURAM CIRCLE,
SUDHA COLONY, PEDDAPURAM-533437
EAST GODAVARI DISTRICT, A.P
...RESPONDENT(S): Counsel for the Petitioner:
SRINIVASA RAO KUDUPUDI Counsel for the Respondent(S):
GP FOR COMMERCIAL TAX
NJS,J & TCDS,J W.P No.24914 of 2026 2
THE HONOURABLE SRI JUSTICE NINALA JAYASURYA THE HONOURABLE SRI JUSTICE T.C.D.SEKH
The judgment continues below.
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