M/S. G M R A Shaha Iron Steels vs. The Assistant Commissioner (State Tax)
Held
The High Court set aside the impugned composite assessment order, ruling that a single show cause notice or assessment order cannot be passed for more than one tax period or financial year under the GST Act. It allowed the respondents to initiate fresh proceedings for each assessment year separately, conditioned on the petitioner depositing 20% of the disputed tax.
Facts
The petitioner challenged a consolidated assessment order (FORM GST DRC-07) and consequential recovery proceedings (DRC-13) issued by the 1st respondent for financial years 2020-21 to 2023-24 under Section 74 of the APGST Act, 2017. The primary contention was that a single composite assessment order covering multiple tax periods was impermissible in law.
Key Issues
The key legal issue was whether a single, composite assessment order could be passed for multiple tax periods or financial years under the provisions of the GST Act.
Sections Cited
Section 74, Section 73, Section 128
AI-generated summary — verify with the full judgment below
APHC010416102026
IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI (Special Original Jurisdiction)
THURSDAY, THE 13th DAY OF AUGUST 2026 PRESENT THE HONOURABLE SRI JUSTICE NINALA JAYASURYA THE HONOURABLE SRI JUSTICE T.C.D.SEKHAR WRIT PETITION NO: 22817 OF 2026 Between:
M/s. G M R A SHAHA IRON STEELS,, Represented by its Proprietor, Mr. Shaik Khaja Peer, DJ'o. 3-153-4-1-2, Opposite APSRTC Anil Parcel Office, Hospital Branch Road, Madanapalle, Annamayya District, Andhra Pradesh - 517325. ...Petitioner AND 1. The Assistant Commissioner State Tax, Madanapalle Circle, Madanapalle - 517 325
The Joint Commissioner State Tax, Kadapa Division, Kadapa
The State of Andhra Pradesh, Represented by its Principal Secretary, Department of Revenue (State Taxes), Secretariat, Velagapudi, Amaravati - 522 238 ...Respondents Petition under Article 226 of the Constitution of India praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased tomaybe pleased to issue an appropriate Writ, Order or Direction, more particularly one in the nature of WRIT OF MANDAMUS declaring the impugned Assessment Order passed
The judgment continues below.
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