Date of reserved for orders : Date of pronouncement : 24.06.2026 Date of uploading : APHC010274342026 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: 16539/2026 Between: 1. M/S UMAR IRON MART, D.NO.5/1028, AGRICULTURE MARKET YARD ROAD, YEMMIGANUR, KJRNOOL DISTRICT, ANDHRA PRADESH-518360. REP.BY ITS SOLE PROPRIETOR, DARJI MAHABOOI BASHA, S/O. DARJI ADBUL JALEEL, AGED ABOUT 37 YEARS, OCC BUSINESS, RIO. DOOR NO.15/.199, CHUNNAM BHATTI STREET, YEMMIGANUR VILLAGE AND MANDAL, KURNOOL DISTRICT. ...PETITIONER AND 1. THE STATE OF ANDHRA PRADESH, REP ITS PRIN IPAL SECRETARY TO GOVERNMENT, REVENUE (COMMERCIAL TAX) DEPARTMENT, GOVERNMENT OF ANDHRA PRADESH. SECRETARIAT, VELAGAPUDI, AMARAVATI. 2. THE CHIEF COMMISSIONER STATE TAXES, ANDHRA PRADESH, GUNTUR. 3. THE ADDITIONAL COMMISSIONER STATE TAXES, TIRUPATI APPELLATE AUTHORITY. 4. THE JOINT COMMISSIONER STATE TAXES, KURNOOL DIVISION. 2 RRR, J & GTK, J W.P.No.16539 of 2026 5. THE ASSISTANT COMMISSIONER STATE TAX, CIRCLE-I, ADONI. ...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 Wirt or writs or order or orders one more particularly in the nature of Writ of Certiorari to call for records pertaining to 3rd respondent CTD Order No. DIN3716022658562 in Form GST APL - 04 dated 16-02-2026 confirming 5th respondent AAO No. GSTIN 37DHKPB0825CIZT dated 01-06-2022 and quash the same and be pleased 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 suspend the operation of the 31d respondents CTD Order No.DIN3716022658562 in Form GST APL-04 dated 16-02-2026 against the petitioner confirming 5th respondents AAO No.GSTI:37DHKPB0825CIZT dated 01-06-2022 and be please to 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 dispense with the filing of the Certified copy of Proceedings vide CTD Order No.DIN3716022658562 in Form GST APL-04 dated 16.02.26, issued by the 3rd respondent herein, in the interest of justice and pass Counsel for the Petitioner: 1. SYED KHADER MASTAN Counsel for the Respondent(S): 1. GP FOR COMMERCIAL TAX 3 RRR, J & GTK, J W.P.No.16539 of 2026 The Court made the following Order: (per Hon’ble Sri Justice R. Raghunandan Rao) Heard Sri Syed Khader Mastan, learned counsel for the petitioner and learned Government Pleader for Commercial Taxes, appearing for the respondents. 2. The petitioner is a registered Company, which has been served with an order of assessment, dated 01.06.2022 passed by the 5th respondent. This order of assessment covers the period from 2019-20 to 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.16539 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 01.06.2022 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.16539 of 2026 81 THE HONOURABLE SRI JUSTICE R RAGHUNANDAN RAO THE HONOURABLE SRI JUSTICE TUHIN KUMAR GEDELA WRIT PETITION NO: 16539/2026 (per Hon’ble Sri Justice R. Raghunandan Rao) Date:24.06.2026 MJA