M/S Satya Trading Enterprises vs. The Superintendent Of Central Tax
Held
The High Court set aside the impugned composite assessment order, holding that a single assessment order cannot be passed for more than one financial year/tax period. The matter was remanded for fresh, separate proceedings for each assessment year, excluding the period of litigation for limitation.
Facts
The petitioner challenged a composite assessment order dated 11.12.2025, covering financial years 2019-20 to 2022-23, arguing it was issued for multiple periods in violation of GST Act provisions and principles of natural justice.
Key Issues
Whether a single composite assessment order covering multiple financial years is legally permissible under Sections 73 and 74 of the GST Act.
Sections Cited
Section 73, Section 74, Rule 142(5), Section 16(4), Section 74(5), Section 73(2), Section 73(3), Section 73(4), Section 73(10)
AI-generated summary — verify with the full judgment below
APHC010202092026
IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI (Special Original Jurisdiction) [3529] WEDNESDAY, THE TWENTY NINETH DAY OF APRIL TWO THOUSAND AND TWENTY SIX PRESENT THE HONOURABLE SRI JUSTICE R RAGHUNANDAN RAO THE HONOURABLE SRI JUSTICE T.C.D.SEKHAR WRIT PETITION NO: 11706/2026 Between:
M/S SATYA TRADING ENTERPRISES, 7-5-130, AYYAPPA SWAMY TEMPLE ROAD MANGAMUR DONKA ONGOLE, PRAKASAM, ANDHRA PRADESH -623002 REP BY ITS MANAGING PARTNER, SMT. NUNNA VENKATA SUDHAKAR
...PETITIONER AND 1. THE SUPERINTENDENT OF CENTRAL TAX, ONGOLE COST RANGE, D.NO. 37-1-413, 3RD FLOOR, ROSHAN PLAZA 8TH LANE, RAM NAGAR ONGOLE -523001. 2. THE ASSISTANT COMMISSIONER OF CENTRAL TAX, CENTRAL GST AUDIT CIRCLE, 2ND FLOOR CRYSTAL, NEAR MADRAS BUS STAND, NELLORE-524003. 3. THE SUPERINTENDENT OF GROUP I, O/O THE ASSISTANT COMMISSIONER OF CENTRAL TAX, CENTRAL GST AUDIT CIRCLE, 2ND FLOOR, ADITI CRYSTAL, NEAR MADRAS BUS STAND, NELLORE-624003. 4. UNION OF INDIA, REP.BY ITS PRINCIPAL SECRETARY, MINISTRY OF FINANCE, 3RD FLOOR, JEEVAN DEEP BUILDING, SANSAD MARG-NEW DELHI-110001. ...RESPONDENT(S):
2 RRR, J & TCDS, J W.P.No.11706 of 2026
Petit
The judgment continues below.
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