Remanded

M/s.Shri Rajalakshmi Textile Processing Mill v. The Assistant Commissioner (St)

Madras HC25 Mar 2026WP/11654/2026

Case brief

AI extract

What is this about?

The High Court disposed of a writ petition by remitting the matter to the tax authority for fresh consideration on merits. The court condoned the limitation delay and directed the petitioner to pre-deposit 10% of the disputed tax and file a reply to the show cause notice within 30 days.

What did the court decide?

Petitioner directed to pre-deposit 10% of disputed tax and file reply within 30 days; matter remitted to Respondent for fresh order on merits.

M/s.Shri Rajalakshmi Textile Processing Mill Vs The… — GST and Indirect Tax | Madras HC (2026)

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1 WP No. 11654 of 2026

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IN THE HIGH COURT OF JUDICATURE AT MADRAS

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DATED: 25-03-2026

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CORAM

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THE HONOURABLE MR JUSTICE C. SARAVANAN

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WP No. 11654 of 2026 and WMP Nos.12700 & 12701 of 2026

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M/s.Shri Rajalakshmi Textile Processing Mill Rep by its Proprietor Palanisamy Nanjappa Gounder, 38-39-40, Perumal Malai Road, Ward 2, Ramanathapuram Pudur Post, Erode, Tamil Nadu- 638 005.

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Petitioner(s)

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The Assistant Commissioner (ST) Chithode Assessment Circle, Erode.

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Respondent(s)

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PRAYER

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Writ Petition filed under Article 226 of the Constitution of India, for issuance of a Writ of Certiorari, calling for the records relating to the impugned proceedings passed by the Respondent in the Order vide GSTIN 33AEDFS3285A1ZD/2021-22 dated 14.12.2025 along with consequential proceedings under section 73 of the act issued in FORM GST DRC 07 vide ref no. ZD331225206145X dated 14.12.2025 for the year 2021-2022 to quash the same and pass.

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https://www.mhc.tn.gov.in/judis

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2 WP No. 11654 of 2026

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For Petitioner(s): Mr.Prashanth N For Respondent (s): Mr.V.Prashanth Kiran Government Advocate

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ORDER

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Mr.V.Prashanth Kiran, learned Government Advocate takes notice for the Respondent.

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This Writ Petition is being disposed of at the stage of admission itself

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with the consent of the learned counsel for the Petitioner and the learned Government Advocate for the Respondent.

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In this Writ Petition, the Petitioner has challenged the impugned Order dated 14.12.2025, which was preceded by a Show Cause Notice in GST DRC-01 dated 27.06.2025 wherein the Petitioner was called upon to file a reply

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and to appear for a personal hearing. However, the Petitioner did not take advantage of the same and has thus suffered the impugned Order dated 14.12.2025.

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It is noticed that the limitation for filing an appeal under Section 107 of

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the respective GST enactments, 2017 against the impugned Order has already

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https://www.mhc.tn.gov.in/judis

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3 WP No. 11654 of 2026

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expired long before. However, the present Writ Petition has been filed only on

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23.03.2026, within the condonable period of limitation.

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At this stage, the learned counsel for the Petitioner submits that the Petitioner is willing to pre-deposit 10% of the disputed tax as a condition for denovo adjudication and he has also made an endorsement to that effect in the Court bundle.

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The learned counsel for the Petitioner has also made an following

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endorsement to that effect in the Court bundle which has been extracted

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hereunder:-

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“I consent to deposit 10% of the disputed tax.”

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Recording the above consent given by the Petitioner, the case is

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remitted back to the Respondent to pass a fresh order on merits subject to the Petitioner depositing 10% of the disputed tax in cash or from the Petitioner's Electronic Cash Register within a period of thirty (30) days from the date of receipt of a copy of this order.

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Within such time, the Petitioner shall also file a reply to the Show Cause Notice in GST DRC-01 dated 27.06.2025 together with requisite documents to substantiate the case by treating the impugned Order dated

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https://www.mhc.tn.gov.in/judis

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4 WP No. 11654 of 2026

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14.12.2025 as an addendum to the Show Cause Notice dated 27.06.2025.

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In case the Petitioner complies with the above stipulations, the

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Respondent shall proceed to pass a final order on merits and in accordance with law as expeditiously as possible, preferably, within a period of three (3) months of such reply/pre-deposit. Subject to the Petitioner complying with the above stipulations, the attachment of the bank account of the Petitioner if any, shall also stand automatically vacated.

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It is made clear that bank attachment shall be lifted subject to the Petitioner depositing 10% of the disputed tax as ordered above and the Petitioner not being in arrears of any other amount for any other tax period barring the amount demanded under the impugned Order.

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In case the Petitioner fails to comply with any of the stipulations, the Respondent is at liberty to proceed against the Petitioner to recover the tax in accordance with law as if this Writ Petition was dismissed in limine today.

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Needless to state, before passing any such order, the Respondent shall give due notice to the Petitioner.

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https://www.mhc.tn.gov.in/judis

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WP No. 11654 of 2026

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

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costs. Connected Writ Miscellaneous Petitions are closed.

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25-03-2026

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Index:Yes/No Speaking/Non-speaking order Internet:Yes Neutral Citation:Yes/No

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The Assistant Commissioner (ST) Chithode Assessment Circle, Erode.

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https://www.mhc.tn.gov.in/judis

WP No. 11654 of 2026

C.SARAVANAN J.

WP No. 11654 of 2026

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25-03-2026

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https://www.mhc.tn.gov.in/judis

M/s.Shri Rajalakshmi Textile Processing Mill v. The Assistant Commissioner (St)

Case brief

What is this about?

What did the court decide?

M/s.Shri Rajalakshmi Textile Processing Mill v. The Assistant Commissioner (St)

Case brief

What is this about?

What did the court decide?

What the court decided

A compact analysis

Issues for consideration

Statutes considered

Parties & counsel

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