Axora Resources LTD vs. The Joint Commissioner Of Central Tax
Held
The High Court, relying on a previous Division Bench ruling, held that a single composite assessment order cannot be passed for more than one tax period or financial year. Consequently, the impugned assessment order was set aside, and the matter was remanded for fresh proceedings for each assessment year separately.
Facts
The petitioner challenged a composite assessment order dated 14.11.2025, covering financial years 2020-21 and 2021-22, and a subsequent recovery notice issued under Section 79 of the APGST Act, 2017. The primary ground of challenge was that a single assessment order for multiple financial years is violative of the GST Act.
Key Issues
Whether a single composite assessment order issued for more than one financial year is permissible under the GST Act, and if such an order is violative of the provisions of Section 73 and Section 74.
Sections Cited
Section 73, Section 74, Section 79
AI-generated summary — verify with the full judgment below
Date of reserved for orders : Date of pronouncement : 24.06.2026 Date of uploading : APHC010313342026
IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI (Special Original Jurisdiction) [3591] WEDNESDAY, THE 24th DAY OF JUNE 2026 PRESENT THE HONOURABLE SRI JUSTICE R RAGHUNANDAN RAO THE HONOURABLE SRI JUSTICE TUHIN KUMAR GEDELA WRIT PETITION NO: 16509/2026 Between:
AXORA RESOURCES LTD, REPRESENTED BY SHRI. P. GANESH KUMAR, SY. NO. 151/1, 151/2, 151/3, 151/4, APIIC INDUSTRIAL PARK, SASTHRI GIRIJANA COLONY THOTTAMBEDU MANDAL, ROUTHUSURAMALA, CHITTOOR, ANDHRA PRADESH - 517 642. ...PETITIONER AND 1. THE JOINT COMMISSIONER OF CENTRAL TAX, TIRUPATI CGST COMMISSIONERATE, 9/86-A, AMARAVATHI NAGAR, WEST CHURCH COMPOUND, TIRUPATI, ANDHRA PRADESH - 517 502. 2. THE ASSISTANT COMMISSIONER ST, SRIKALAHASTI CIRCLE, SY. NO.253, GROUND FLOOR,
GOKULAM GRAND BUILDING, PANAGAL, SRIKALAHASTI - 517 640. 3. UNION OF INDIA, DEPARTMENT OF REVENUE, REPRESENTED BY ITS SECRETARY (REVENUE), NORTH BLOCK, NEW DELHI - 110
THE STATE OF ANDHRA PRADESH, REPRESENTED BY ITS PRINCIPAL SECRETARY, REVENUE DEPARTMENT (COMMERCIAL TAX) A.P. SECRETA
The judgment continues below.
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