Facts of the Case
The petitioner, Pohtireddy Venkata Reddy, a registered
taxpayer under the GST law, challenged an Order-in-Original dated 24.09.2025
passed under Section 74 of the CGST/APGST Act, 2017. The impugned order
covered the tax periods from FY 2021-22 to FY 2024-25 through a single
composite assessment order.
The proceedings originated from a Show Cause Notice in Form
GST DRC-01 dated 16.06.2025, also issued under Section 74, alleging
differential GST liability relating to works contract services provided to
the State Government. Subsequently, the authorities attached the
petitioner's bank account, recovered ₹65.10 lakh, and placed a lien on
the remaining demand.
Aggrieved by the composite adjudication, the petitioner
approached the Andhra Pradesh High Court under Article 226 of the
Constitution of India, seeking quashing of the assessment order, the show
cause notice, and the consequential recovery proceedings.
Issues Involved
- Whether
a single show cause notice and composite assessment order under Section
74 of the CGST/APGST Act can validly cover multiple financial years.
- Whether
clubbing adjudication for four assessment years violates the statutory
framework under Sections 73 and 74.
- Whether
such composite proceedings violate the principles of natural justice.
- Whether
recovery proceedings based on such an assessment order are sustainable.
Petitioner's Arguments
- The
assessment order covering four financial years through a single
adjudication was contrary to the provisions of Sections 73 and 74
of the GST Acts.
- The
authorities failed to consider the petitioner's explanation before passing
the assessment order.
- The
dispute regarding differential tax on works contract services was wrongly
adjudicated through one consolidated proceeding instead of separate
proceedings for each assessment year.
- The
composite assessment suffered from procedural irregularity, lack of
jurisdiction, and violation of natural justice.
- Consequently,
the attachment of the bank account and recovery proceedings were also
liable to be quashed.
Respondent's Arguments
- The
State defended the assessment proceedings initiated under Section 74.
- It
relied upon the assessment order and the consequential recovery
proceedings.
- However,
during the hearing, the principal legal issue centred on the
maintainability of a single composite assessment order covering
multiple tax periods, particularly in light of earlier judicial
precedents of the Andhra Pradesh High Court.
Court Order / Findings
The Andhra Pradesh High Court referred to its earlier decision
in W.P. No.11028 of 2025 & batch, wherein it had categorically held
that:
- A single
show cause notice or
- A single
composite assessment order
cannot be issued for more than one tax period. Where
annual returns have become due, each financial year must be assessed
separately.
Applying the above principle, the Court held that the impugned
assessment order covering FY 2021-22 to FY 2024-25 through one composite
order was legally unsustainable.
Accordingly, the High Court:
- Set
aside the assessment order dated 24.09.2025.
- Remanded
the matter to the GST authorities.
- Granted
liberty to initiate fresh assessment proceedings separately for each
assessment year.
- Directed
that the petitioner shall deposit 20% of the disputed tax within six
weeks.
- Ordered
that any amount already recovered shall be adjusted against the said 20%
deposit.
- Directed
exclusion of the period between the original assessment order and receipt
of the High Court order while computing limitation for fresh proceedings.
- Left
all other legal contentions of the petitioner open for consideration in
the fresh proceedings.
Important Clarification
This judgment reiterates an important procedural safeguard
under the GST law:
- Each
assessment year constitutes a separate tax period for adjudication.
- GST
authorities cannot issue a consolidated show cause notice or assessment
order covering multiple financial years after the annual return due
date.
- If
such composite proceedings are initiated, they are liable to be set aside.
- However,
the tax authorities retain the liberty to initiate fresh independent
proceedings for each assessment year, subject to statutory limitation
and the directions issued by the Court.
- The
Court balanced the interests of both the taxpayer and the Revenue by
directing a 20% deposit of the disputed tax while remanding the
matter.
Sections Involved
- Article
226 of the Constitution of India
- Section
74 of the Central Goods and Services Tax Act, 2017
- Section
74 of the Andhra Pradesh Goods and Services Tax Act, 2017
- Section
73 of the Central Goods and Services Tax Act, 2017
- Section
73 of the Andhra Pradesh Goods and Services Tax Act, 2017
- Form GST DRC-01
Link to Download the Order
https://www.mytaxexpert.co.in/uploads/1784870320_1934compressed.pdf
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