Writ appeal challenging an order rejecting exclusion of the COVID-19 limitation period for quasi-judicial GST proceedings under Sections 73/74. The Division Bench held that the Supreme Court's clarification in suo motu W.P.No.3 of 2020 extends the exclusion to such proceedings and dismissed the appeal.
This page shows the compact analysis of this judgement. The full analysis — procedural history, issue-by-issue holdings with ratio and obiter, advocates, and paragraph-level evidence for every claim — is being added to the record in batches and will appear here when this judgement has been through it.
W.A.No.3080 of 2025
IN THE HIGH COURT OF JUDICATURE AT MADRAS
DATED : 17.10.2025
CORAM :
THE HONOURABLE MR. JUSTICE M.S. RAMESH AND THE HONOURABLE MR. JUSTICE R.SAKTHIVEL
W.A.No.3080 of 2025
M/s.Oasys Cybernetics Pvt. Ltd., No.3 OAS Towers, Stringers Road, Vepery, Chennai-600 003
... Appellant
Vs.
State Tax Officer, Vepery Assessment Circle, Room No.A-110, 1st Floor, PAPJM Building No.1 Greams Road, Chennai-600 006
... Respondent
PRAYER: Appeal is filed under Clause 15 of the Letters Patent, praying
to set aside the order passed in W.P.No.37331 of 2024 dated 12.06.2025, read with the clarification issued on 14.07.2025 as the said orders are arbitrary against public policy and in violation of Articles 14 and 19 (1)(g)
Page 1 of 6
W.A.No.3080 of 2025
of the Constitution.
| For Appellant | : Mr.G.Natarajan |
|---|---|
| For Respondent | : Mr.Haja Nazirudeen Additional Advocate General |
| assisted by Mr.C.Harsha Raj Special Government Pleader |
|
| and Mr.V.Prashanth Kiran | |
| Government Advocate |
JUDGMENT
(Judgment of this Court was delivered by M.S.RAMESH.J)
This Writ Appeal has been filed to set aside the order passed in W.P.No.37331 of 2024 dated 12.06.2025, read with the clarification issued
on 14.07.2025, as the said orders are arbitrary against public policy and in violation of Articles 14 and 19 (1)(g) of the Constitution of India.
Page 2 of 6
W.A.No.3080 of 2025
15.03.2020 and 28.02.2022, stood excluded for the purposes of calculating limitation in respect of any judicial / quasi judicial proceedings, would cease to have effect with the introduction of Section 168A of the CGST / SGST Act and the issuance of Notification No.13 of 2022, were rejected.
contend that the limitation prescribed under Section 73 of the Act, would not apply to quasi judicial proceedings and that the same will apply only to the limitation for the litigants in various proceedings.
“I. The order dated 23.03.2020 is restored and in continuation of the subsequent orders dated 08.03.2021, 27.04.2021 and 23.09.2021, it is directed that the period from 15.03.2020 till 28.02.2022 shall stand excluded for the purposes of limitation as may be prescribed under any general or special laws in respect of all judicial or quasi-judicial proceedings.”
Page 3 of 6
W.A.No.3080 of 2025
may not have merits in view of the Hon'ble Supreme Court's clarification, extending the exclusion of the limitation to quasi judicial proceedings,
which includes the proceedings under Section 73 and 74 of the Act.
[M.S.R., J] [R.S.V.,J]
17.10.2025
Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No Anu
Page 4 of 6
W.A.No.3080 of 2025
To
State Tax Officer, Vepery Assessment Circle, Room No.A-110, 1st Floor, PAPJM Building No.1 Greams Road, Chennai-600 006
Page 5 of 6
W.A.No.3080 of 2025
M.S.RAMESH, J. and R.SAKTHIVEL, J. Anu
W.A.No.3080 of 2025
17.10.2025
Page 6 of 6
1 issue framed by the court
Whether the Supreme Court's limitation-exclusion period (15.03.2020 to 28.02.2022) applies to quasi-judicial GST proceedings under Sections 73/74 despite Section 168A and Notification No.13 of 2022.
Colour shows how this judgement treated each authority
suo motu Writ Petition No.3 of 2020 dated 10.01.2022Relied on¶4
4 provisions across 2 enactments
M/s.Oasys Cybernetics Pvt. Ltd.
State Tax Officer, Vepery Assessment Circle
M.S.Ramesh
R.Sakthivel
As recorded by the court registry
Judgements on the same questions, provisions and authorities, from every court
