Date of reserved for orders : Date of pronouncement : 24.06.2026 Date of uploading : APHC010313342026 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: 16509/2026 Between: 1. AXORA RESOURCES LTD, REPRESENTED BY SHRI. P. GANESH KUMAR, SY. NO. 151/1, 151/2, 151/3, 151/4, APIIC INDUSTRIAL PARK, SASTHRI GIRIJANA COLONY THOTTAMBEDU MANDAL, ROUTHUSURAMALA, CHITTOOR, ANDHRA PRADESH - 517 642. ...PETITIONER AND 1. THE JOINT COMMISSIONER OF CENTRAL TAX, TIRUPATI CGST COMMISSIONERATE, 9/86-A, AMARAVATHI NAGAR, WEST CHURCH COMPOUND, TIRUPATI, ANDHRA PRADESH - 517 502. 2. THE ASSISTANT COMMISSIONER ST, SRIKALAHASTI CIRCLE, SY. NO.253, GROUND FLOOR, GOKULAM GRAND BUILDING, PANAGAL, SRIKALAHASTI - 517 640. 3. UNION OF INDIA, DEPARTMENT OF REVENUE, REPRESENTED BY ITS SECRETARY (REVENUE), NORTH BLOCK, NEW DELHI - 110 001. 4. THE STATE OF ANDHRA PRADESH, REPRESENTED BY ITS PRINCIPAL SECRETARY, REVENUE DEPARTMENT (COMMERCIAL TAX) A.P. SECRETARIAT, VELEGAPUDI - 522 238. 2 RRR, J & GTK, J W.P. No.16509 of 2026 ...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 a writ of mandamus or any other writ, direction or order quashing the proceedings of the 1 Respondent in the Single AND Composite Adjudication Order passed vide 010 No. 15/2025-26 COST dated 14.11.2025 for a period of two years from FY 2020-21 to FY 2021-22 as without jurisdiction, unreasonable, impermissible, against the principles of natural justice, violative of Article 14 of the Constitution of India and contrary to the provisions of the COST Act, 2017 B. Consequently, the Honble Court may set aside and quash the Recovery Notice under Section 79 of the APGST Act, 2017 dated 11.06.2026 issued by the 2ND Respondent for recovery of the demand confirmed in the impugned order C. 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 leased to stay the operation of the proceedings of the 1ST Respondent in OlO No. 15/2025-26 CGST dated 14.11.2025, in the interest of justice, in the interest of justice and pass IA NO: 2 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 the proceedings of the 2ND Respondent in Recovery Notice issued under Section 79 of the APGST Act, 2017 dated 11.06.2026, in the interest of justice and pass Counsel for the Petitioner: 1. ANIL KUMAR BEZAWADA Counsel for the Respondent(S): 1. SANTHI CHANDRA 2. GP FOR COMMERCIAL TAX 3 RRR, J & GTK, J W.P. No.16509 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 14.11.2025 passed by the 1st respondent. This order of assessment covers the periods 2020-21 and 2021-22. 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 & GTK, J W.P. No.16509 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 14.11.2025 and remand back to the respondents, leaving it open to the respondents to initiate fresh proceedings, for each assessment year separately. All issues are left open to be adjudicated before the Assessing Authority. 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 ________________________ TUHIN KUMAR GEDELA, J Date:24.06.2026 MJA 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.16509 of 2026 74 THE HONOURABLE SRI JUSTICE R RAGHUNANDAN RAO THE HONOURABLE SRI JUSTICE TUHIN KUMAR GEDELA WRIT PETITION NO: 16509/2026 (per Hon’ble Sri Justice R. Raghunandan Rao) Date:24.06.2026 MJA