M/S.Shri Nandhi Dhall Mills India Private Limited Vs… — Writ and Judicial Review | Madras HC (2025)

M/S.Shri Nandhi Dhall Mills India Private Limited Vs… — Writ and Judicial Review | Madras HC (2025)

What the court decided

AI extract

Outcome

Liberty to file statutory appeal(s) against the respective impugned orders before the Appellate Authority within 30 days of receipt of a copy of the order, subject to production of proof of payment of 25% of the disputed tax confirmed under each impugned order; on such compliance the Appellate Authority is to entertain the appeal and decide it on merits on its own turn without reference to limitation; all issues left open; no costs; connected Writ Miscellaneous Petitions closed.

Issue for consideration

Whether the impugned Form DRC-07 orders dated 21.10.2024 bearing Ref Nos.ZD331024148569C, ZD331024148476J, ZD331024148361W, ZD331024148658D passed by the 1st respondent for financial years 2019-20, 2020-21, 2021-22 and 2022-23 are liable to be quashed (challenged by way of Writ of Certiorari in WP.Nos.19435, 19436, 19438 and 19441 of 2025). +1 more

Ratio / Principle

All the Writ Petitions are disposed of by this common order after recording the request of the learned counsel for the Petitioner that the Petitioner may be given liberty to redress the grievance on merits before the Appellate Tribunal.

Key takeaways

Liberty is granted to the Petitioner to file a statutory appeal against the respective impugned orders within 30 days from the date of receipt of a copy of this order.ratio¶26
At the time of filing the appeals, the Petitioner shall produce the necessary documents to substantiate that it has already paid 25% of the disputed tax confirmed under each of the impugned orders.ratio¶28
On the Petitioner complying with the stipulated pre-deposit proof, the Appellate Authority shall entertain the appeal and dispose of it on merits on its own turn without further reference to the aspect of limitation; all the issues are left open to be canvassed before the Appellate Authority.

Detailed headnote1 paragraphs

High Court of Madras (Justice C. Saravanan), common order dated 27.11.2025 disposing of WP.Nos.19435, 19436, 19438, 19441 and 19444 of 2025 filed by M/s. Shri Nandhi Dhall Mills India Private Limited against (i) four Form DRC-07 orders dated 21.10.2024 bearing Ref Nos.ZD331024148569C, ZD331024148476J, ZD331024148361W and ZD331024148658D passed by the State Tax Officer (Intelligence), Inspection Cell-2, Salem for financial years 2019-20, 2020-21, 2021-22 and 2022-23, and (ii) a communication dated 07.04.2025 of Axis Bank marking a lien of Rs.29,48,288/- on the Petitioner's Account No.916020019086112. Recording counsel's request for liberty to pursue the grievance before the Appellate Tribunal, and noting compliance with the Court's interim order dated 28.05.2025 whereby the impugned orders stood stayed subject to deposit of 25% of the disputed tax, the Court disposed of the petitions granting liberty to file statutory appeals within 30 days; proof of the 25% pre-deposit is to be produced at the time of filing; on compliance the Appellate Authority is to entertain the appeals and dispose of them on merits without reference to limitation; all issues left open. No costs; connected WMPs closed.

IN THE HIGH COURT OF JUDICATURE AT MADRAS

DATED : 27.11.2025

CORAM :

THE HONOURABLE MR.JUSTICE C.SARAVANAN

WP.Nos.19435, 19436, 19438, 19441 and 19444 of 2025 and WMP. No.21698, 21701, 21704, 21708 and 21715 of 2025

M/s. Shri Nandhi Dhall Mills India Private Limited, represented by its Director Mr.B.Selvarathinam, No.270, Narasimman Road, Shevapet, Salem 636 002. …. Petitioner in all WPs Vs.

The State Tax Officer (Intelligence) Inspection cell-2, Office of the Joint Commissioner (ST), Intelligence, Salem, Commercial Taxes Building, Hasthampatti, Salem 636 007.

The State Tax Officer (Intelligence), Inspection Cell-4, Integrated commercial Taxes Building, 2^nd Floor, Pitchards Road, Hasthampatti, Salem 636 007.

Axis Bank, Agraharam Branch, No.116 and 118, Sabari Palace, 2^nd Agraharam, Salem 636 001.

.. Respondents in all Wps.

Prayer in WP.Nos. 19435, 19436, 19438, 19441 of 2025 : Writ Petitions filed

under Article 226 of the Constitution of India praying for issuance of Writ of Certiorari to call for the records pertaining tot he impugned order in Form DRC

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07 all dated 21.10.2024 bearing Ref Nos.ZD331024148569C, ZD331024148476J, ZD331024148361W, ZD331024148658D, passed by the 1^st respondent for the financial years 2019-20, 2020-21, 2021-22, 2022-23, and quash the same.

Prayer in W.P.No.19444 of 2025: Writ Petition filed under Article 226 of the Constitution of India praying for issuance of Writ of Certiorari to call for the records pertaining to the impugned communication dated 07.04.2025 issued by the 3^rd respondent, whereby, a lien of Rs.29,48,288/- was marked on Account No.916020019086112 maintained by the Petitioner and quash the same.

For Petitioner in all cases : Mr. Hari Radhakrishnan

For Respondents in all cases : Mr.T.N.C.Kaushik,

Additional Government Pleader (T) COMMON ORDER

By this common order, all these Writ Petitions are being disposed of, after recording the request of the learned counsel for the Petitioner that Petitioner may be given liberty to redress the grievance on merits before the Appellate Tribunal.

Learned Counsel for the Petitioner further submits that the Petitioner

has also complied with the Order dated 28.05.2025 of this Court wherein, the impugned orders were stayed subject to the Petitioner depositing 25% of the disputed tax confirmed under the respective impugned Orders.

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Recording the same, Writ Petition stands disposed by granting liberty

to the Petitioner to file a statutory appeal against the respective impugned orders

within 30 days from the date of receipt of a copy of this order.

At the time of filing of appeals, the Petitioner shall produce necessary documents to substantiate that the Petitioner has indeed already paid 25% of the disputed tax confirmed under each of the impugned orders.

5. In case Petitioner complies with the above stipulation, the Appellate Authority shall entertain the appeal and dispose of the same on merits on its own turn without further reference to the aspect of limitation. All the issues are left open to be canvassed before the Appellate Authority. petitions are closed.

This Writ Petition stands disposed of with the above observations. No

costs. Connected Writ Miscellaneous Petitions are closed.

Neutral Citation : Yes / No 27.11.2025 onn gv

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C.SARAVANAN.,J gv

To:

The State Tax Officer (Intelligence) Inspection cell-2,

Office of the Joint Commissioner (ST), Intelligence, Salem, Commercial Taxes Building, Hasthampatti, Salem 636 007.

The State Tax Officer (Intelligence), Inspection Cell-4, Integrated commercial Taxes Building, 2^nd Floor, Pitchards Road, Hasthampatti, Salem 636 007.

Axis Bank, Agraharam Branch, No.116 and 118, Sabari Palace,

2^nd Agraharam, Salem 636 001.

WP.Nos.19435, 19436, 19438, 19441 and 19444 of 2025 and WMP. No.21698, 21701, 21704, 21708 and 21715 of 2025

27.11.2025

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