Madras High Court
Tvl Supreme Garnet vs The Deputy State Tax Officer on 17 March, 2026
Author: D.Bharatha Chakravarthy
Bench: D.Bharatha Chakravarthy
W.P(MD)No. 7432 of 2026
BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT
DATED :17.03.2026
CORAM:
THE HONOURABLE MR JUSTICE D.BHARATHA CHAKRAVARTHY
W.P(MD)No. 7432 of 2026
and
W.M.P.(MD) No.6108 of 2026
Tvl Supreme Garnet, IMC
rep. by its Parner S.Chandresan. ... Petitioner
Vs
The Deputy State Tax Officer-1,
Nanguneri Assessment Circle,
Nanguneri. ... Respondent
PRAYER: Writ Petition filed under Article 226 of the Constitution of
India, praying this Court to issue a Writ of Certiorari calling for the
records in the impugned Order in GSTIN Ref No. 33AAAFI9714R1ZX/
2020-21 dated 11.11.2024 issued by the Respondent and quash the same
as it is without jurisdiction and clear violation of Statutory provisions.
For Petitioner : Mr. S Karunakar
For Respondent : Mr.R.Suresh Kumar
Additional Government Pleader
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W.P(MD)No. 7432 of 2026
ORDER
This writ petition is filed challenging the impugned order dated 11.11.2024. By the said order passed under Section 73 of the TNGST Act, 2017, for the tax period 2020-21, it is noted there are certain defects, including mismatch between GSTR 3B and GSTR 2A, etc.
2. The learned counsel for the petitioner submits that as the entire exercise was conducted only by uploading the show cause notice and the order in the portal, the petitioner could not make use of the opportunity.
3. The learned Additional Government Pleader would submit that as per the Act and the rules framed thereunder, uploading of the show cause notice as well as the order amounts to service and therefore, without availing the opportunity, belatedly, the present writ petition is being filed.
4. I have considered the rival submissions made on either side and perused the assessment order, the grounds on which the defects are noted 2/5 https://www.mhc.tn.gov.in/judis ( Uploaded on: 25/03/2026 12:00:13 pm ) W.P(MD)No. 7432 of 2026 and the tax liability on the other heads imposed. I have also considered the reason that is mentioned in the affidavit filed in support of the writ petition for not participating in the assessment proceedings.
5. On an overall consideration of the facts and circumstances of the case, I am of the view that one opportunity can be granted to the petitioner, however, on condition to deposit 25% of the disputed tax amount.
6. In view thereof, this writ petition is allowed on the following terms:
(a) Within four (4) weeks from the date of receipt of the web copy of the order, without waiting for the certified copy of the order, the petitioner shall deposit 25% of the disputed tax amount;
(b) Upon such deposit, the impugned order, dated 11.11.2024 shall stand set aside and the matter is remanded back to the file of the respondent for fresh disposal;
(c) It will be open for the petitioner to appear before the respondent and file a reply and also place on record such documents in 3/5 https://www.mhc.tn.gov.in/judis ( Uploaded on: 25/03/2026 12:00:13 pm ) W.P(MD)No. 7432 of 2026 support of its claim and to raise all grounds, both factual and legal, before the respondent;
(d) It is for the respondent to consider and pass orders afresh in accordance with law; and
(e) No costs. Consequently, connected miscellaneous petition is closed.
NCC : Yes/No 17.03.2026
apd
To
The Deputy State Tax Officer-1,
Nanguneri Assessment Circle,
Nanguneri.
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W.P(MD)No. 7432 of 2026
D.BHARATHA CHAKRAVARTHY.,J.
apd
ORDER MADE IN
W.P(MD)No. 7432 of 2026
17.03.2026
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