Date of reserved for orders : Date of pronouncement :24.06.2026 Date of uploading : APHC010304312026 IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI (Special Original Jurisdiction) [3591] WEDNESDAY, THE 24th DAY OF JUNE 2026 PRESENT THE HONOURABLE SRI JUSTICE R RAGHUNANDAN RAO THE HONOURABLE SRI JUSTICE TUHIN KUMAR GEDELA WRIT PETITION NO: 16136/2026 Between: 1. GIRIRAJ GRANITES, REP. BY ITS MANAGING PARTNER RAVIPUDI RAJA RAMAN S/O LAKSHMI NARAYANA AGED ABOUT 39 YEARS, R/O FACTORY SY. NO. 412/2, RAJUPALEM, BALLIKURAVA MANDAL, BAPATLA DISTRICT- 532203. ...PETITIONER AND 1. THE STATE OF ANDHRA PRADESH, REP.BY ITS PRINCIPAL SECRETARY, REVENUE (CT) DEPARTMENT, A.P.SECRETARIAT, AMARAVATHI -522238. 2. THE DEPUTY ASSISTANT COMMISSIONER OF THE STATE TAX, GUNTUR MEDICAL COLLEGE RD, KANNA VARI THOTA, GUNTUR- 522004. 3. THE ASSISTANT COMMISSIONER OF STATE TAX, D.NO 5-37- 111,2ND FLOOR, SUBBA REDDY COMPLEX 4/17 BRODIPET, GUNTUR-522002 4. THE ASSISTANT COMMISSIONER OF CENTRAL TAX, GST BHAVAN, D.NO.3-30-15, RING ROAD, GUNTUR-522006 ...RESPONDENT(S): 2 RRR,J & GTK,J W.P.No.16136 of 2026 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 tomay be pleased to issue a Writ of Mandamus or any other appropriate Writ, Order or Direction, declaring the action of the Respondent No.3 in issuing the impugned order in Form GST DRC-07 vide Ref. No. ZD3704260278172 dated 21.04.2026 as illegal. arbitrary, without authority of law and violative of the provisions of the Central Goods and Services Tax Act, 2017 and the Andhra Pradesh Goods and Services Tax Act, 2017, and in violation of the principles of natural justice, and consequently set aside the impugned order vide dated 21.04.2026 and all consequential proceedings arising therefrom, and pass such 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 Counsel for the Petitioner: 1. SOMISETTY GANESH BABU Counsel for the Respondent(S): 1. GP FOR REVENUE 3 RRR,J & GTK,J W.P.No.16136 of 2026 The Court made the following Order: (per Hon’ble Sri Justice R. Raghunandan Rao) Heard Sri Somisetty Ganesh Babu, the learned counsel appearing for the petitioner and 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 21.04.2026. This Order of Assessment, covers the tax period from 2021-2022 to 2025-2026. 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 & GTK,J W.P.No.16136 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 21.04.2026, 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. ________________________ R. RAGHUNANDAN RAO, J ________________________ TUHIN KUMAR GEDELA, J Date:24.06.2026 KPV Whether the order is : Speaking Yes/No / Recorded Yes/No Reportable Yes/No / Non-Reportable Yes/No 5 RRR,J & GTK,J W.P.No.16136 of 2026 85 THE HON’BLE SRI JUSTICE R. RAGHUNANDAN RAO AND THE HONOURABLE SRI JUSTICE TUHIN KUMAR GEDELA WRIT PETITION No.16136 of 2026 (per Hon’ble Sri Justice R. Raghunandan Rao) 24.06.2026 KPV