Facts of the case:
The petitioner challenged Orders-in-Original passed by the assessing authority between 31.12.2025 and 01.01.2026 for five different assessment years. It was contended that although separate assessment orders were issued, they were passed simultaneously, effectively defeating the principles laid down by the Kerala High Court in Lakshmi Mobiles Accessories and Tharayil Medicals, which had deprecated the practice of clubbing multiple assessment years through composite notices and composite assessment orders. The petitioner also raised several grounds challenging the merits of the assessments.
Issue:
Whether the simultaneous passing of separate assessment orders for different assessment years is invalid merely because all such orders were issued together, and whether such action violates the principles laid down against composite assessment proceedings.
Held That:
The High Court dismissed the writ petition and held that there is no statutory prohibition against passing separate assessment orders simultaneously for different assessment years.
The Court clarified that its earlier decisions in Lakshmi Mobiles Accessories and Tharayil Medicals were directed against the practice of issuing composite notices and composite assessment orders, which prejudice the assessee by clubbing multiple assessment years into a single proceeding.
Since the assessing authority had issued separate notices and separate assessment orders for each assessment year and had afforded the petitioner an opportunity to file objections, the mere fact that the orders were passed on the same day or within a short span did not render them illegal.
The Court further declined to examine the merits of the assessments, holding that such issues should be agitated before the statutory appellate authority. Accordingly, the writ petition was dismissed, leaving the petitioner at liberty to avail the statutory remedy of appeal.
Case Name: THOTTUNGAL ANOOP BABU SURESHBABU Versus AUDIT OFFICER, TEAM 4, AUDIT DIVISION-II, STATE GOODS AND SERVICES TAX DEPARTMENT, POOTHOLE, THRISSUR AND OTHERS dated 07.07.2026
To read the complete judgement 2026 Taxo.online 1925
