Tvl. Global Systems vs. The State Tax Officer

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WP(MD)/13814/2026HC MadrasGSTCNR HCMD01063518202630 April 2026Bench: HONOURABLE MR JUSTICE D.BHARATHA CHAKRAVARTHY6 pages

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Before: and

This writ petition is filed challenging the impugned order dated 03.12.2025, which is an assessment order passed under Section 73 of the TNGST Act, 2017. 2. Heard Mr.A.Satheesh Murugan, learned counsel appearing for the petitioner and Mr.R.Suresh Kumar, learned Additional Government Pleader, who takes notice on behalf of the respondent. 3.Upon perusal of the impugned order, it can be seen that when there was mismatch between GSTR 3B and GSTR 2A, the petitioner did not avail the opportunity, when the show cause notice was uploaded and the final order was passed. Accordingly, the impugned order came to be passed ex-parte. 2 https://www.mhc.tn.gov.in/judis

4.

It is contended on behalf of the petitioner that, although the petitioner filed a reply, they did not avail themselves of the opportunity to submit the documents in support of their claim. The impugned order has been passed, and it is now stated that the petitioner is ready to file the documents before the authority. This Court has been extending such opportunities on equitable grounds; however, under appropriate conditions. Therefore, an opportunity is granted to the petitioner assessee on the condition of depositing 25% of the disputed tax amount.

5.

In view of this, the writ petition is allowed on the following terms:- i. Within four weeks of receiving the web copy of the order, the petitioner shall deposit 25% of the disputed tax amount with the respondent, without waiting for a certified copy of the order. ii. Upon such deposit, the impugned order dated 03.12.2025 shall stand set aside, and the matter shall stand remanded back to the file of the respondent. iii. The assessee shall appear before the respondent without fail and submit their reply and documents in support of their claim, and it is for the respondent to consider the matter afresh and pass orders in accordance with law. 3 https://www.mhc.tn.gov.in/judis iv. Since the impugned order of assessment is set aside, any attachment of the bank account made pursuant to the impugned order shall stand raised. v. No costs. Consequently the connected miscellaneous petitions shall stand closed. 30.04.2026 NCC:Yes/No rgm 4 https://www.mhc.tn.gov.in/judis To The Deputy State Tax Officer-2 Pudukottai -1 Assessment Circle, Commercial Taxes Buildings, Pudukottai. 5 https://www.mhc.tn.gov.in/judis D.BHARATHA CHAKRAVARTHY, J. rgm and W.M.P(MD)No.10262 of 2026 30.04.2026 6 https://www.mhc.tn.gov.in/judis

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.