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AP HC Quashes Bhaarath Group Multi‑Year Composite GST Assessment Order: Directs Fresh Year‑Wise Proceedings with 20% Pre‑Deposit [Read Order]

The order brings relief to the company from immediate recovery of dues totaling ₹16.71 crore, comprising tax, penalty, and interest, while reaffirming the principle that each financial year must be assessed independently under the GST law.

Gopika V
AP HC Quashes Bhaarath Group Multi‑Year Composite GST Assessment Order: Directs Fresh Year‑Wise Proceedings with 20% Pre‑Deposit [Read Order]
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In a recent ruling, the Andhra Pradesh High Court at Amaravati has set aside a composite GST assessment order issued against Bhaarath Group Private Limited, holding that a single order covering multiple financial years violates the provisions of the GST Act, 2017. The petitioner stated that the department’s composite order was impermissible under the law and amounted to...


In a recent ruling, the Andhra Pradesh High Court at Amaravati has set aside a composite GST assessment order issued against Bhaarath Group Private Limited, holding that a single order covering multiple financial years violates the provisions of the GST Act, 2017.

The petitioner stated that the department’s composite order was impermissible under the law and amounted to a violation of principles of natural justice, as it was passed without a proper opportunity to respond. The company also challenged the subsequent attachment notice (GST DRC‑17) issued in January 2026, calling it arbitrary and without jurisdiction.

The division bench comprising Justice R. Raghunandan Rao and Justice T.C.D. Sekhar observed that the assessment order dated 05 July 2022, passed by the Assistant Commissioner of State Tax, Vijayawada, spanned five financial years, 2017‑18 to 2021‑22, contrary to Sections 73 and 74 of the Act, which mandate separate proceedings for each tax period.

The Court referred to its earlier decision in SJ Constructions v. State Tax Department (2025 SCC OnLine AP 3334), which held that a single show‑cause notice or composite assessment order cannot be issued for multiple tax periods. Following that precedent, the bench quashed the impugned order and remanded the matter to the tax authorities for fresh, year‑wise assessments.

Importantly, the Court directed that the petitioner must deposit 20% of the disputed tax amount before the department initiates new proceedings. Any payments already made will be adjusted against this pre‑deposit. The bench also set aside all coercive recovery actions and attachment notices, clarifying that the time between the original order and this judgment will be excluded for limitation purposes.

The Court has finished the main matter, so any pending related requests are also considered closed

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M/S.BHAARAT GROUP PRIVATE LIMITED vs ASSISTANT COMMISSIONER ST, BENZ CIRCLE , 2026 TAXSCAN (HC) 680 , WRIT PETITION NO: 7121/2026 , 6 May 2026 , THANJAVURU VENKATA SUMAN , GP FOR COMMERCIAL TAX
M/S.BHAARAT GROUP PRIVATE LIMITED vs ASSISTANT COMMISSIONER ST, BENZ CIRCLE
CITATION :  2026 TAXSCAN (HC) 680Case Number :  WRIT PETITION NO: 7121/2026Date of Judgement :  6 May 2026Coram :  HONOURABLE SRI JUSTICE R RAGHUNANDAN RAO & HONOURABLE SRI JUSTICE T.C.D.SEKHARCounsel of Appellant :  THANJAVURU VENKATA SUMANCounsel Of Respondent :  GP FOR COMMERCIAL TAX
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