Andhra Pradesh High Court Quashes Multi-Year GST Assessment

Bhaarat Group Private Limited, based in Nagarjuna Nagar, Vijayawada, decided they had had enough and took their fight to the Andhra Pradesh High Court at Amaravati. Leading the charge was Rajasekar, the director and son of Venkata Subba Reddy. They filed Writ Petition No. 7121 of 2026 because they were fed up with an assessment order dated July 5, 2022. The Assistant Commissioner of State Tax at Benz Circle, No. II Division, Vijayawada, had squeezed five financial years – 2017-18 through 2021-22 –  into a single assessment order. GST law simply does not allow that. The total demand slapped on them? Rs. 16,71,86,886, broken down into Rs. 6,79,78,066 for tax, an equal amount for penalty, plus Rs. 3,12,30,754 in interest.

On May 6, 2026, a Division Bench  Justice R. Raghunandan Rao and Justice T.C.D. Sekhar heard the case. Sri T.V. Suman represented the company, while the Government Pleader for Commercial Tax represented the other side.

Bhaarat Group’s argument was clear and straightforward: you can’t just bunch up several years and shoot out one big assessment order. Sections 73 and 74 of the GST Act, 2017, say so quite plainly, and the High Court spelt it out in SJ Constructions (2025 SCC Online 3334). There was more the Bhaarat Group said the order blindsided them, giving them no chance to explain or defend themselves, which flies in the face of natural justice. They also protested the property attachment notice in Form GST DRC-17, issued on January 28, 2026, which had followed from this illegal order.

After hearing both sides, Writ Petition is disposed of, setting aside the impugned order. They leaned on their previous decision in W.P. Nos. 11028 of 2025 and others and made it clear: you can’t cover more than one tax period, no matter if it’s monthly or yearly, with a single show-cause notice or assessment order. Because of this, the Court tossed out the composite assessment order from July 5, 2022, and scrapped all recovery actions, including the property attachment. The GST authorities now have to redo everything, issuing separate proceedings for each year. But the Bhaarat Group isn’t off the hook entirely  they have to deposit 20% of the disputed tax, though any earlier payments count towards this. The Bench also made sure the time lost in the middle won’t count against them for limitation purposes. No costs were awarded, and all miscellaneous applications were closed.

GST authorities can’t cut corners. They must stick to the rules and give taxpayers a fair shot for each year. No more clubbing years together.