APHC010256892026 IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI (Special Original Jurisdiction) [3529] FRIDAY,THE EIGHTH 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: 13637/2026 Between: 1. M/S CRANTYA GEOSPATIAL PRIVATE LIMITED, D. NO WILLOW 506, RAINTREE PARK, DWARAKA KRISHNA OPP. NAGARJUNA UNIVERSITY, NEW PATTABHIPURAM GUNTUR DISTRICT - 522508 REPRESENTED BY ITS AUTHORIZED SIGNATORY MR. I CHALAPATI RAO ...PETITIONER AND 1. THE DEPUTY ASSISTANT COMMISSIONER ST, PEDAKAKANI CIRCLE, GUNTUR - I DIVISION GUNTUR, ANDHRA PRADESH 2. THE STATE OF ANDHRA PRADESH, REP BY ITS PRINCIPAL SECRETARY REVENUE (CT) DEPT., VELAGAPUDI, AMARAVATI - 522 238 ...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 appropriate Writ, Order or Direction, more particularly one in the nature of WRIT OF MANDAMUS declaring the impugned Assessment Order vide FORM GST DRC - 07 Dt. 02.09.2024 passed by the 1st Respondent for the tax periods 2020- 21 and 2022-23 in a consolidated manner as illegal, arbitrary, violative of Principles of Natural 2 RRR,J & TCDS,J W.P.No.13637 of 2026 Justice, Article 14, 21 and 300-A of the Constitution of India and Consequently Set aside the same or 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 operation of impugned Assessment Order FORM GST DRC - 07 Dt. 02.09.2024 passed by the 1St Respondent for the tax periods 2020-21 and 2022-23 in a consolidated manner pending disposal of the present Writ Petition or to pass Counsel for the Petitioner: 1. ISMAIL SHAIK Counsel for the Respondent(S): 1. GP FOR COMMERCIAL TAX 2. 3 RRR,J & TCDS,J W.P.No.13637 of 2026 The Court made the following Order: (per Hon’ble Sri Justice R. Raghunandan Rao) Heard Sri Ismail Shaik, the learned counsel appearing for the petitioner and Sri S. A. V. Sai Kumar, the learned Government Pleader for Commercial Taxes, appearing for the respondents. 2. The petitioner is a registered Company, which has been served with an Order, dated 02.09.2024, in FORM GST DRC – 07, passed by the 1st respondent. This Order of Assessment, covers the period, 2020-2021 & 2022-2023. 3. The petitioner, after having raised various grounds of challenge, has pressed 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. 4 RRR,J & TCDS,J W.P.No.13637 of 2026 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, dated 02.09.2024, leaving it open to the respondents to initiate fresh proceedings, for each assessment year separately. 7. This order shall be subject to the condition of the petitioner depositing 20% of the disputed tax within a period of three (03) weeks from the date of receipt of this order. Any payment made, by the petitioner, after the impugned order, had been passed, shall be set off, for the purpose of calculating the aforesaid 20%. 8. 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. ________________________ R. RAGHUNANDAN RAO, J _________________ T.C.D. SEKHAR, J Date:08.05.2026 KPV 5 RRR,J & TCDS,J W.P.No.13637 of 2026 177 THE HON’BLE SRI JUSTICE R. RAGHUNANDAN RAO AND THE HON'BLE SRI JUSTICE T.C.D.SEKHAR WRIT PETITION No.13637 of 2026 (per Hon’ble Sri Justice R. Raghunandan Rao) 08.05.2026 KPV