M/S Greenfy INDIA vs. Additional Commissioner
Held
The Court, relying on its previous Division Bench judgment, held that a single composite assessment order cannot be passed for more than one tax period or financial year. Consequently, the impugned order was set aside, and the respondents were permitted to initiate fresh, separate proceedings for each assessment year, with the period from the impugned order to this judgment excluded for limitation.
Facts
The petitioner challenged a consolidated assessment order passed under Section 74 of the GST Act for the period January 2020 to September 2022, arguing it was illegal, time-barred, violated natural justice, and was invalid for covering multiple financial years in a single order. The High Court focused on the ground of the order being a composite one for multiple years.
Key Issues
The primary legal issue was whether a single, composite assessment order could be validly issued under Sections 73 and 74 of the GST Act for multiple financial years or tax periods.
Sections Cited
Section 73, Section 74
AI-generated summary — verify with the full judgment below
APHC010233582026
IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI (Special Original Jurisdiction) [3529] WEDNESDAY, THE SEVENTEENTH DAY OF JUNE TWO THOUSAND AND TWENTY SIX PRESENT THE HONOURABLE SRI JUSTICE R RAGHUNANDAN RAO THE HONOURABLE SRI JUSTICE T.C.D.SEKHAR WRIT PETITION NO: 12704/2026 Between:
M/S GREENFY INDIA, REP. BY ITS MANAGING PARTNER, MRS. B. NAGA SUBHASHINI, 1-48, GROUND FLOOR, MUNAGAPAKA, MACHERLA, GUNTUR-522 426. ...PETITIONER AND 1. ADDITIONAL COMMISSIONER, VISAKHAPATNAM CENTRAL GST COMMISSIONERATE,
GST BHAVAN, PORT AREA, VISAKHAPATNAM-530 035. 2. UNION OF INDIA, REP. BY ITS SECRETARY, MINISTRY OF FINANCE, 3RD FLOOR, JEEVAN DEEP BUILDING SANSAD MARG, NEW DELHI-110 001. 3. STATE OF ANDHRA PRADESH, REP. BY ITS PRINCIPAL SECRETARY TO GOVERNMENT, REVENUE (CT-II) DEPARTMENT, SECRETARIAT, VELAGAPUDI, AMARAVATHI, GUNTUR DISTRICT- 522 237. 4. DIRECTORATE GENERAL OF GST INTELLIGENCE, VISAKHAPATNAM ZONAL UNIT, VISAKHAPATNAM-530 020. ...RESPONDENT(S): 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 2 RRR
The judgment continues below.
Read the full judgment
A free account opens 10 full GST judgments a month (one account works on both bharattax.net and this site). Re-reading one you have already opened does not count again.
The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.
Reproduced from the public record of the Andhra Pradesh High Court. Verify against the court's own copy before relying on it. Income tax judgments are on bharattax.net.