M/S Sea 6 Energy Private Limited vs. Assistant Commissioner Of Central Taxes
Held
The Court held that the expression 'relevant period' must be construed consistently for all terms in the refund formula, including Net ITC and turnover. The petitioner was permitted to file a fresh application due to a misconception in applying the formula.
Facts
The petitioner, a manufacturer of biostimulants and potash, claimed a refund of accumulated Input Tax Credit (ITC) on zero-rated exports for March 2025. The claim was partially allowed, leading to the present writ petition.
Key Issues
The key issue was the consistent interpretation of the 'relevant period' in the refund formula for calculating Net ITC and turnover. The petitioner sought to apply it differently for each component.
Sections Cited
Section 54, Rule 89(4)
AI-generated summary — verify with the full judgment below
BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT DATED : 21.11.2025 CORAM THE HONOURABLE MR.JUSTICE G.R.SWAMINATHAN & W.M.P.(MD)No.20444 of 2025 M/s.Sea 6 Energy Private Limited, C-50 SIPCOT Industrial Complex, Tuticorin 628 008. ... Respondent Prayer : Writ Petition filed under Article 226 of the Constitution of India, praying this Court to issue a Writ of Certiorarified Mandamus, quashing the impugned order in form GST-RFD 6 Dated 24.06.2025 passed by the respondent as the same being contrary to the provisions of Section 54 of the CGST Act, Section 16 of the IGST Act and Rule 89(4) of the CGST Rules and also in contravention of articles 14, 19(1)(g) and 265 of the Constitution and direct the respondent to sanction the refund as claimed by the petitioner. 1/6 https://www.mhc.tn.gov.in/judis For Petitioner : Mr.G.Natarajan For Respondent : Mr.R.Gowri Shanka
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