M/S.Muthukumar.R vs. The Deputy State Tax Officer-2

After considering the arguments of the learned counsel appearing for the petitioner and perusing the material records of the case, it can be seen that the impugned order has been passed on three heads. Firstly, it is stated that the petitioner has claimed ineligible input tax credit. In this regard, it is the finding of the authority that, though the petitioner had filed a reply, no supporting documents were produced. 2 https://www.mhc.tn.gov.in/judis

Secondly, with reference to the interest component, the learned counsel appearing for the petitioner would submit that an earlier order dated 22.01.2026 had already been passed, whereby the authorities accepted the contention of the petitioner that the interest liability had also been paid.

The third issue relates to general interest and penalty. The learned Additional Government Pleader would submit that it is for the assessee to satisfy the assessing authority by producing documents in support of their claim.

I have considered the rival submissions made on either side and perused the material records of the case.

Considering the fact that the very liability with reference to the payment of interest is disputed, and that the other head has also been decided against the assessee solely on the ground that no supporting documents were produced, I am of the view that an opportunity can be granted to the assessee. 3 https://www.mhc.tn.gov.in/judis

Normally, while granting such an opportunity, this Court imposes a condition directing deposit of 25% of the disputed tax amount. However, since it is stated that 15% of the disputed tax amount has already been paid, the writ petition is ordered on the following terms:- i. Within a period of four weeks from the date of receipt of a web copy of the order, the petitioner shall deposit 10% of the disputed tax amount. ii. Upon such deposit, the impugned order dated 11.06.2025 shall stand set aside and the matter shall stand remanded back to the file of the respondent. iii. The petitioner shall file such additional reply and produce such document in support of its claim and it will be open for the petitioner even to raise the issue with reference to the interest portion by bringing to the notice of the authority of the earlier 4 https://www.mhc.tn.gov.in/judis order dated 22.01.2026 and it is for the authority to consider the entire issue afresh and pass orders thereon in accordance with law. iv. No costs. Consequently, connected miscellaneous petition is closed. 21.04.2026 Neutral Citation: No rgm To The Deputy State Tax Officer -2, Commercial Tax Building, Aruppukottai. 5 https://www.mhc.tn.gov.in/judis D.BHARATHA CHAKRAVARTHY