Srirangam Traders vs. The Deputy Commissioner (GST Appeals) (State Tax)
Held
The Court held that the impugned assessment order dated 24.10.2025 was unsustainable and contrary to the provisions of the respective GST enactment. The reasoning was that the order confirmed an amount in excess of the proposal contained in the Show Cause Notice. The ratio decidendi is that an authority cannot confirm a demand that exceeds the amount initially proposed in the Show Cause Notice without issuing a revised or supplementary notice. Consequently, the Court quashed the impugned order dated 24.10.2025 and remitted the matter back to the second respondent (State Tax Officer) to pass fresh orders on merits and in accordance with law. The second respondent was directed to afford an opportunity of hearing to the petitioner before passing the fresh order, which was to be completed within three months from the date of receipt of a copy of the Court's order. The issue regarding the rejection of the rectification application was implicitly addressed by the remand.
Facts
The petitioner, Srirangam Traders, filed a writ petition challenging an assessment order dated 24.10.2025 passed by the State Tax Officer (2nd respondent). This order confirmed the proposals made in a Show Cause Notice dated 19.06.2025. The petitioner also challenged the subsequent rejection of their rectification application by an order dated 13.02.2026. The core of the petitioner's grievance is that the impugned assessment order confirmed an amount in excess of what was proposed in the Show Cause Notice. The petitioner sought to quash these orders and requested a fresh show cause notice and an opportunity for enquiry.
Key Issues
1. Whether the impugned assessment order, which confirmed an amount in excess of the proposal in the Show Cause Notice, is sustainable under the GST enactments? The petitioner argued that the assessment order was unsustainable and contrary to the provisions of the GST enactment because it confirmed a demand exceeding the amount specified in the Show Cause Notice. The petitioner contended that this procedural irregularity vitiated the order and that they should be provided with a fresh opportunity to present their case. The revenue or State did not record any specific arguments in the judgment regarding this issue.
Sections Cited
DRC-01
AI-generated summary — verify with the full judgment below
__________ Page1 of 4 BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT DATED: 25-08-2026 CORAM THE HON'BLE MR JUSTICE C. SARAVANAN and W.M.P.(MD)Nos.18202 and 18204 of 2026 Srirangam Traders Rep by its Partner, Arachamveettil Abdul Malik, S/o. Haji.A.Abdul Rasheed, No.72/735-B, Sumaya Complex, Periyar Nagar, Suttamalli, Tirunelveli ..Petitioner(s) Vs
The Deputy Commissioner (GST Appeals) (State Tax) CT Buildings, A.R.Line Road, Palayamkottai, Tirunelveli
The State Tax Officer (State Tax) Department of Commercial Taxes, Tirunelveli Town Assessment Circle, Tirunelveli ..Respondent(s) Writ Petition filed under Article 226 of the Constitution of India, praying this court to issue a Writ of Certiorarified Mandamus calling for the records pursuant to the impugned assessment order of the 2nd respondent vide Reference No. ZD331025246361V dated 24.10.2025 and the consequential impugned order of rejection of the petitioner rectification application vide Ref No. ZD330226110069T dated 13.02.2026 and quash the same and consequentially direct the 2nd respondent issue fresh show cause notice and proceed further for enquiry, after pr
The judgment continues below.
Read the full judgment
A free account opens 10 full GST judgments a month (one account works on both bharattax.net and this site). Re-reading one you have already opened does not count again.
The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.
Reproduced from the public record of the Madras High Court. Verify against the court's own copy before relying on it. Income tax judgments are on bharattax.net.