APHC010171082026 IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI (Special Original Jurisdiction) [3529] TUESDAY,THE SEVENTH 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: 8685/2026 Between: 1. GURU RAGHAVENDRA INFRASTRUCTURE, REP BY ITS MANAGING PARTNER, DAGUMATI VENKATA KRISHNA REDDY R/O PLOT NO. 118 AND 119, SRI RAGHAVENDRA COLONY, KAVALI, SPSR NELLORE, ANDHRA PRADESH - 524201. ...PETITIONER AND 1. THE UNION OF INDIA, REP BY ITS SECRETARY, MINISTRY OF FINANCE, DEPARTMENT OF REVENUE NORTH BLOCK, NEW DELHI - 110001. 2. THE COMMISSIONER OF CENTRAL TAX, , G.S.T. BHAVAN, KANNAVARI THOTA, GUNTUR - 522004. ANDHRA PRADESH. 3. THE ADDITIONAL COMMISSIONER OF CENTRAL TAX, OFFICE OF THE COMMISSIONER OF CENTRAL TAX, G.S.T. BHAVAN, KANNAVARI THOTA, GUNTUR - 522004, ANDHRA PRADESH. ...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 pleased topleased to issue an order or a direction or a writ, more one in the nature of Writ of Mandamus, holding the Order 0/0. No.GUN-GST-OOO- ADC- 101/2025-26-GST dated 30-12-2025 of the Respondent No.3 (Additional Commissioner, Office of the Commissioner of Central Tax, 2 RRR,J & TCDS,J W.P.No.8685 of 2026 Guntur), as arbitrary, illegal, ultra vires, and Unconstitutiona l and to consequentially to set aside the same and pass IA NO: 1 OF 2026 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 Stay the 0/0. No.GUN-GST-000-ADC-101/2025-26-GST dated 30- 12-2025 of the Respondent No.3 (Additional Commissioner, Office of the Commissioner of Central Tax, Guntur), pending disposal of the main writ petition and pass Counsel for the Petitioner: 1. T SREEDHAR Counsel for the Respondent(S): 1. The Court made the following: 3 RRR,J & TCDS,J W.P.No.8685 of 2026 The Court made the following Order: (per Hon’ble Sri Justice R. Raghunandan Rao) Heard Sri.Anil Kumar Bezawada, learned counsel for the petitioner and Smt.Santhi Chandra learned standing counsel, appearing for the respondents. 2. The petitioner is a registered Company, which has been served with an order of assessment, dated 30.12.2025, passed by the 2nd respondent. This order of assessment covers the period from 2018-19 to 2023-24. 3. The petitioner, after having raised various grounds of challenge, has pressed the ground that, a single order of assessment, issued for more than one financial year, would be violative of the provisions of Section 73 and Section 74 of the GST Act, 2017, and consequently, set aside the impugned order of assessment. 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 of assessment being 4 RRR,J & TCDS,J W.P.No.8685 of 2026 a composite order of assessment. 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 impugned order of assessment, dated 30.12.2025, and remand back to the respondents, leaving it open to the respondents to initiate fresh proceedings, for each assessment year separately. Needless to say, the period from the date of issuance of the impugned order of assessment till the date of receipt of this order shall be excluded for the purposes of limitation. There shall be no order as to costs. As a sequel, pending miscellaneous applications, if any, shall stand closed. ________________________ R. RAGHUNANDAN RAO, J _________________ T.C.D. SEKHAR, J Date:07.04.2026 CMK