(Prayer: 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 topleased to issue a Writ of Mandamus or any other appropriate writ or order or direction declaring the action of the 1 Respondent in passing the order for the period July 2017 to January 2022 as a composite assessment order 29.11.2022, composite show cause dated 9.9.2022 and not affixing the signatures either digitally or physically the show cause notice and the order and summaries thereof, as confirmed by the 2nd Respondent in the appeal by composite order dated 23.1.2025 under the Central Goods and Service Tax Act, 2017 by as illegal, arbitrary, contrary to law and without jurisdiction and consequently set aside the show cause notice in DRC -01 dated 9.9.2022, assessment order dated 29.11.2022 passed by the 1st Respondent and also the appellate order dated 23.1.2025 passed by the 2nd Respondent for the period July 2017 to January 2022 as illegal, arbitrary, contrary to law, without jurisdiction and in gross violation of principles of natural justice, and consequently direct the 1st Respondent to reassess the Petitioner in accordance with law, in the interest of justice, and pass

IA NO: 1 OF 2025

Petition under Section 151 CPC praying that in the circumstances stated in the affidavit filed in support of the petition, the High Court may be pleased pleased to suspend the garnishee notice dated 5.12.2025 issued by the 1st Respondent to the 5th Respondent Bank for recovery of the alleged arrears for the period 2017-18 to 2022-23 under the Goods and Service Tax Act, 2017, in the interest of justice, as otherwise the Petitioner will be put to irreparable loss and hardship, pending disposal of the Writ Petition.

IA NO: 2 OF 2025

Petition under Section 151 CPC praying that in the circumstances stated in the affidavit filed in support of the petition, the High Court may be pleased pleased to grant stay of recovery of the disputed demand pursuant to the impugned assessment order dated 29.11.2022 as affirmed in the appellate order dated 23.1.2025 for the tax period July 2017 to January 2022 under the Goods and Service Tax Act, 2017, pending disposal of the Writ Petition as otherwise the Petitioner will be put to severe loss and hardship.)

R. Raghunandan Rao, J.

1. Heard Sri Srinivasa Rao Kudupudi, learned counsel for the petitioner and the learned Government Pleader for Commercial Tax appearing for the respondents.

2. The petitioner is a registered Company, which has been served with an Order of assessment, dated 29.11.2022, passed by the 1st respondent. This Order of assessment covers the period from July 2017 to January 2022. Aggrieved by this Order, the petitioner had filed an appeal which came to be dismissed on 23.01.2025. The petitioner has approached this Court challenging the Order of assessment, dated 29.11.2022 as well as the Order of appeal, dated 23.01.2025.

3. The petitioner, after having raised various grounds of challenge, have sought a direction, on the ground that, a single assessment order passed, for more than one financial year, would be violative of the provisions of Section 73 and Section 74 of the G.S.T. Act, 2017, and consequently, set aside the orders of assessment/appeals.

4. A Division Bench of this Court, in W.P.No.11028 of 2025 & batch, after considering the said question, had held that, a single show-cause notice or a single composite assessment order, cannot be passed, in relation to more than one tax period of either a month if the assessment is taken up before the due date for filing of the annual return or for more than one year if the due date for filing of annual return has been reached.

5. The petitioner has raised various grounds of challenge. However, the petitioner is pressing the primary ground of the order being a composite order. In that view of the matter the present Writ Petition is being disposed of on this ground of challenge, leaving open the other grounds of challenge.

6. Accordingly, this Writ Petition is disposed of, setting aside the Order of assessment, dated 29.11.2022 as well as the Order of appeal, dated 23.01.2025, leaving it open to the respondents to initiate fresh proceedings, for each assessment year separately.

7. Needless to say, the period from the date of passing of the impugned order till the date of receipt of this order shall be excluded for the purpose of limitation. There shall be no order as to costs.

                  As a sequel, pending miscellaneous applications, if any, shall stand closed.