APHC010198512026 IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI (Special Original Jurisdiction) [3529] TUESDAY, THE FIFTH DAY OF MAY TWO THOUSAND AND TWENTY SIX PRESENT THE HONOURABLE SRI JUSTICE R RAGHUNANDAN RAO THE HONOURABLE SRI JUSTICE T.C.D.SEKHAR WRIT PETITION NO: 11340/2026 Between: 1. RAMBO COMMUNICATIONS, REPRESENTED BY THE KARTHA OF THE HUF (PROPRIETOR) SRI RENTALA VENKATA NARAYANA, ROOM NO.4, POLICE CLUB ROOMS, POLICE COMPLEX, ANANTAPUR, ANDHRA PRADESH 515001 ...PETITIONER AND 1. ASSISTANT DIRECTOR, O/O DIRECTOR GENERAL OF GST INTELLIGENCE, DOOR NO28-14-17, SURYABAGH, BESIDE MELODY THEATRE, VISAKHAPATNAM, ANDHRA PRADESH - PIN 520 020. 2. THE ASSISTANT COMMISSIONER OF CENTRAL TAX, ANANTAPUR CGST DIVISION, DOOR NO 28-999, 1ST FLOOR, GST BHAWAN, BESIDE MONTESSORI SCHOOL, SANGAMESH NAGAR, ANANTAPUR, ANDHRA PRADESH. - PIN 515001, 3. UNION OF INDIA, REPRESENTED BY THE SECRETARY TO GOVERNMENT OF INDIA MINISTRY OF FINANCE, REVENUE DEPARTMENT, NORTH BLOCK, CENTRAL SECRETARIAT, NEW DELHI-PIN 110 001. ...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, J & TCDS, J W.P.No.11340 of 2026 pleased topleased to issue an appropriate writ, order or direction, more in the nature of Writ of Mandamus, setting aside the common claimed composite show- cause Notice dated 26-06-2025 and its composite claimed summary in Form GST DRC-01 dated 27-06-2025, the claimed composite orders in- original No-17/2025 GST (ACT), dated 29-10-2025 and its claimed 6 summaries in Form GST DRC- 07 dated 04-12-2025 issued under Section 74 of the CGST Acts, 2017, the APGST Acts, 2017 and the IGST Act, 2017 by the Respondent No1 and to 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 collection of the disputed tax of Rs. 128.08,100 + Rs. 1,04,000 and the penalty of Rs. 128,08,100 + Rs. 128,08,100, besides the unquantified interest; and to pass Counsel for the Petitioner: 1. J.N VENKATA SURESH KUMAR Counsel for the Respondent(S): 1. SANTHI CHANDRA 3 RRR, J & TCDS, J W.P.No.11340 of 2026 The Court made the following Order: (per Hon’ble Sri Justice R. Raghunandan Rao) Heard Sri J.N. Venkata Suresh Kumar, 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 29.10.2025 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 a composite order of assessment. In that view of the matter, the present Writ 4 RRR, J & TCDS, J W.P.No.11340 of 2026 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 29.10.2025 and remand back to the respondents, leaving it open to the respondents to initiate fresh proceedings, for each assessment year separately. This order is subject to the condition of the petitioner depositing 20% of the disputed tax, within a period of six (06) weeks. Any payment made or any amount recovered from the petitioner, after the passing of the impugned order, shall be adjusted against the aforesaid 20%. 7. 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:05.05.2026 MJA 5 RRR, J & TCDS, J W.P.No.11340 of 2026 202 THE HONOURABLE SRI JUSTICE R RAGHUNANDAN RAO THE HONOURABLE SRI JUSTICE T.C.D.SEKHAR WRIT PETITION NO: 11340/2026 (per Hon’ble Sri Justice R. Raghunandan Rao) Date:05.05.2026 MJA