Madras High Court
Smt R Ashaarajaa vs The Senior Intelligence Officer on 21 July, 2025
Author: Krishnan Ramasamy
Bench: Krishnan Ramasamy
W.P.No.29716 of 2024, etc., batch
IN THE HIGH COURT OF JUDICATURE AT MADRAS
Dated : 21.07.2025
CORAM
THE HON'BLE Mr. JUSTICE KRISHNAN RAMASAMY
W.P.Nos.29716, 29720, 29726 & 34137 of 2024
& 2270, 3597, 7616, 7644, 7646, 7766, 9000, 9001,
9100, 12084, 12988, 13600, 13959, 14805, 15215,
15499, 16111, 16840, 16845, 16852, 19849, 19857,
19861, 20367, 22277, 22281 & 22808 of 2025
and
W.M.P.Nos.32378, 32375, 32384, 36953 & 36954 of 2024
& 2609, 2610, 3988, 8544, 8573, 8576, 8722, 10108,
10111, 10215, 18478, 13647, 13648, 14492, 15262,
15713, 16709, 17165, 17511, 18242, 19089, 19096,
19108, 22372, 22382, 22391, 22955, 25062, 25061,
25069, 25067 & 25627 of 2025
W.P.Nos.29716 of 2024:
Smt R Ashaarajaa
Partner of M/s JRD Realtorss
Q-121, Kovaipudur,
Coimbatore-641 042
... Petitioner
Vs.
1.The Senior Intelligence Officer
Directorate General Of Gst Intelligence,
Coimbatore Zonal Unit,
155-1, Lakshmanan Street,
Ukkadam, Coimbatore-641 001
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W.P.No.29716 of 2024, etc., batch
2.The Superintendent of Central Tax CGST
Central Excise
Coimbatore III D Range Buildings,
141 Srinivasa Nagar, SIDCO Industrial Estate,
Kuruchi, SIDCO Post Office, Coimbatore.
... Respondents
Prayer:
Writ Petition filed under Article 226 of the Constitution of India
praying to issue a Writ of Certiorari, call for the records pertaining to the
impugned Show Cause Notice No.131/2024-GST dated 31.07.2024 read
with Form GST DRC-01 Ref. no. ZD330824009536E dated 02.08.2024
was issued by the 1st Respondent and quash the same.
W.P.Nos.29720 of 2024:
J.Rajendran
PARTNER OF M/S.JRD.REALTORSS,
Q-121, Kovaipudur, Coimbatore-641042
... Petitioner
Vs.
1.The Senior Intelligence Officer
Directorate General Of Gst Intelligence,
Coimbatore Zonal Unit,
155-1, Lakshmanan Street,
Ukkadam, Coimbatore-641 001
2.The Assistant / Deputy Commissioner of
Central Tax and Central Excise
Coimbatore III Division, Elgi Building,
144, Trichy Road, Sungam Post Office,
Coimbatore
... Respondents
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W.P.No.29716 of 2024, etc., batch
Prayer:
Writ Petition filed under Article 226 of the Constitution of India
praying to issue a Writ of Certiorari, call for the records pertaining to the
impugned Show Cause Notice No.130/2024-GST dated 31.7.2024 read
with Form GST DRC 01 reference No. ZD3308240094986 dated
1.8.2024 was issued by 1st Respondent and quash the same
W.P.Nos.29726 of 2024:
R.Deepak Vigneshvar
Partner Of M/s.Jrd Realtorss,
Q-121, Kovaipudur,
Coimbatore-641 042
... Petitioner
Vs.
1.The Additional Director
Directorate General Of Gst Intelligence,
Coimbatore Zonal Unit, 155-1,
Lakshmanan Street, Ukkadam,
Coimbatore-641 001
2.The Additional Joint Commissioner of
Central Tax and Central Excise
GST Commissionerate, 6/7 ATD Street,
Racecourse, Coimbatore.
... Respondents
Prayer:
Writ Petition filed under Article 226 of the Constitution of India
praying to issue a Writ of Certiorari, call for the records pertaining to the
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W.P.No.29716 of 2024, etc., batch
impugned Show Cause Notice No. 129/2024-GST dated 31.07.2024 read
with Form GST DRC-01 ref. no. ZD330824009360R dated 02.08.2024
was issued by the 1st Respondent and quash the same
W.P.Nos.34137 of 2024:
Shri. Angusamy Subbu Rathinam,
Proprietor, M/s. Cholaa Knit Wear,
5, Kg Layout, Kongu Main Road,
Tirupur-641607.
... Petitioner
Vs.
1.The Superintendent,
Coimbatore Audit Circle 1,
Rakavis Towers, 1065,Trichy Road,
Coimbatore -641045.
2.The Superintendent Of Gst And Central Excise,
Tirupur Ii Range, 1st Floor,
51, Elementary School Street,
Kumar Nagar, Tirupur-641603.
3.The Assistant Commissioner,
Office Of The Assistant Commissioner Of Gst
And Central Excise, Tirupur Division,
2nd Floor, Elementary School Street,
Kumar Nagar, Tirupur-641603.
... Respondents
Prayer:
Writ Petition filed under Article 226 of the Constitution of India
praying to issue a Writ of Certiorari, calling for the records on the files
of the 2nd respondent in OC No. 06/2024 dated 25.4.24 (Order Sl. No.
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W.P.No.29716 of 2024, etc., batch
01/2024 - GST) and quash the same as being without jurisdiction and
hence invalid and illegal
W.P.Nos.2270 of 2025:
Tamilnadu Water Supply and Drainage Board
Rep. by its Managing Director,
V.Dakshinamoorthy, TWAD House
31 Kamarajar Salai Chepauk
Chennai-600 005
... Petitioner
Vs.
1.The Union of India
Rep. by the Secretary,
Department of Revenue,
Ministry of Finance,
No.137, North Block,
New Delhi-1010 001.
2.The Good and Services Tax Council
GST Council Secretariat,
rep. by its Chairman,
5th Floor Tower
II JeevanBharati Building
Janpath Road Connaught Palace
New Delhi 110001
3.The Central Board of Indirect Taxes and Customs
rep. by its director
CBIC North Block
New Delhi 110001
4.The Additional Commissioner
office of the principal commissioenr of CGST
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W.P.No.29716 of 2024, etc., batch
and Central Excise,
Chennai North Commissionerate
Chennai 600 034
... Respondents
Prayer:
Writ Petition filed under Article 226 of the Constitution of India
praying to issue a Writ of Certiorari, calling for the records of the
impugned order passed in DIN 20250159TK0000023749 dated 02 01
2025 on the file of the 4th Respondent and quash the same
W.P.Nos.3597 of 2025:
Tamilnadu Water Supply and Drainage Board
Rep. by its Managing Director,
V.Dakshinamoorthy, TWAD House
31 Kamarajar Salai Chepauk
Chennai-600 005
... Petitioner
Vs.
1.The Union of India
Rep. by the Secretary,
Department of Revenue,
Ministry of Finance, No.137,
North Block, New Delhi-1010 001.
2.The Goods and Services Tax Council
5th floor Tower II
Jeevan Bharati Building
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W.P.No.29716 of 2024, etc., batch
Janpath Road
Connaught Palace
New Delhi 110001
3.The Central Board of Indirect Taxes and Customs
CBIC North Block
New Delhi 110001
4.The Additional Commissioner
Chennai North Commissionerate
Chennai 600034
5.The State of Tamil Nadu
Fort St George Chennai 600009
... Respondents
Prayer:
Writ Petition filed under Article 226 of the Constitution of India
praying to issue a Writ of Certiorari, calling for the records in G.O.(Ms.)
No. 1 dated 02.01.2024 issued by the 5th Respondent and quash the
same
W.P.Nos.7616 of 2025:
Mobility Aids Sales and Services,
Door No.2, Ground Floor,
Masilamani Nagar 2nd Street,
Kanniamman Koil Main Road,
Vanagaram, Maduravoyal, Chennai
Rep By Its Prop Sri Padmanabhan
... Petitioner
Vs.
1.The Deputy Commissioner (HPU)
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W.P.No.29716 of 2024, etc., batch
Chennai South Commissionerate,
No. 692 Mhu Complex,
Nandanam, Chennai 600 035.
2.The Assistant Commissioner of GST and CE,
Valasaravakkam Division,
Chennai South Commissionerate,
Newry Towers, No.2054,
I Block, II Avenue, 12th Main Road,
Anna Nagar, Chennai .
... Respondents
Prayer:
Writ Petition filed under Article 226 of the Constitution of India
praying to issue a Writ of Certiorari, call for the records relating to the
Order in Original No.04/2025-AC (GST)in DIN 20250159TL000000E
9E5 dated 31-1-2025 passed by the 2nd respondent and to quash the
same as issued without authority, and contrary to law and thus render
justice
W.P.Nos.7644 of 2025:
George Maijo Industries Pvt Ltd
Represented By Its Managing Director Shri.
Maijo Joseph, 2b, Apex Plaza,
3rd Floor, No.5, Nungambakkam High Road,
Nungambakkan, Chennai-600 034
... Petitioner
Vs.
The Additional Commissioner Of Central Tax
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W.P.No.29716 of 2024, etc., batch
Chennai North Commissionerate,
No.26/1,Mahatma Gandhi Road,
Chennai-600 034
... Respondents
Prayer:
Writ Petition filed under Article 226 of the Constitution of India
praying to issue a Writ of Certiorari, calling for the records in Order -in-
Original No.51/2025-GST-CHN(ADC) dated 30.01.2025 along with
summary of the order in DRC 07 bearing Reference No
ZD3302250123804 dated 03.02.2025, passed by the Respondent and
quash as the same having been passed contrary to law, contrary to facts,
in violation of the principles of natural justice without considering the
detailed defiance put forth by the Petitioner and also violative of Art.14,
19 (1) (g) and 265 of the Constitution
W.P.Nos.7646 of 2025:
M/S K2 Cranes and Components Pvt limited
Rep. By Its Director C. Raju
No 352/1a Uthiramerur Road,
Pukkathurai, Kancheepuram District 603 308
... Petitioner
Vs.
1.The Deputy Commissioner
Audit Ii Commissionerate,
Mhu Complex, Anna Salai,
Nandanam, Chennai 600 035
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W.P.No.29716 of 2024, etc., batch
2.The Assistant Commissioner GST AND CE.,
Villupuram Division, ( Maduranthakam Rage)
Chennai Outer Commissionerate, BSNL Campus,
Hospital Road, Villupuram 605 602
... Respondents
Prayer:
Writ Petition filed under Article 226 of the Constitution of India
praying to issue a Writ of Certiorari, call for the records relating to the
Order-in-Original No.39/2023 (GST) dated 29/12/2023 in DIN
20231259XL110011161D enclosed along with Form GST DRC-07 in
Reference No ZD330524002533X dated 02/05/2024 issued by the 2nd
respondent and to quash the same as arbitrary, violative of principles of
natural justice and contrary to law and thus render justice
W.P.Nos.7766 of 2025:
M/S.Vizza Insurance Broking Services Pvt Ltd
Represented by its Managing Director,
Mr.K. Sundar, Seventh Floor,
Old No.304, 305 and New No.443, 445,
Annexe II Building, Anna Salai
Teynampet, Chennai - 600018
... Petitioner
Vs.
The Deputy Commissioner
Office of the Deputy Commissioner of CGST
and Central Excise,
Thyagaraya Nagar Division,
Chennai South Commissionerate
692, M.H.U. complex,
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W.P.No.29716 of 2024, etc., batch
Anna Salai Nandanam, Chennai- 35.
... Respondents
Prayer:
Writ Petition filed under Article 226 of the Constitution of India
praying to issue a Writ of Certiorari, calling for the records in Order-in-
Original No. 40/2023-GST dated 31.08.2023 on the file of the
Respondent for the F.Ys. 2017-18, 2018-19 and 2019-20 and quash the
same.
W.P.Nos.9000 & 9001 of 2025:
Ms Idea Granites
Rep by its Authorised Signatory
Shri Vishnu Kant Soni,
No. 715 64, Pillaihkothur Village,
Shoolagiri Taluk, Krishnagiri District,
Tamil Nadu 635126
... Petitioner
Vs.
The Additional Commissioner GST
Office of the commissioner of GST and
Central Excise, GST Bhawan
No 1 Foulkes Compound,
Anaimedu, salem 636 001
... Respondents
Prayer:
Writ Petition filed under Article 226 of the Constitution of India
11/69
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W.P.No.29716 of 2024, etc., batch
praying to issue a Writ of Certiorari, calling for the records relating to
Order-in-Original Sl. No. 26/2025 GST (ADC) in File No.
GEXCOM/ADJN/GST/ADC/2080/2024-ADJN in DIN
20250259XP000000C160 dt. 03.02.2025 passed by the Respondent,
quash the same, and pass any such further or other orders as this Honble
Court
calling for the records relating to Order-in-Original SI. No.
26/2025 GST (ADC) in File No.GEXCOM/ADJN/GST/ADC/ 2080/
2024-ADJN in DIN 20250259XP000000C160 dt. 03.02.2025 passed by
the Respondent, quash the same, and pass any such further or other
orders as this Honble Court
W.P.No.9100 of 2025:
TVL.Balaji Modern Rice Mill
Represented by Its Partner Mr.V.Balaji
No.1, T.H.Road, Kokkumedu,
Tiruvallur, Tamil Nadu 601 204.
... Petitioner
Vs.
The Additional Commissioner
Office of the commissioner central Excise and
GST, Newry Towers,
No. 2054-I, II Avenue,
Anna Nagar, chennai- 40.
... Respondents
Prayer:
Writ Petition filed under Article 226 of the Constitution of India
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W.P.No.29716 of 2024, etc., batch
praying to issue a Writ of Certiorari, calling for the records of the
Impugned Order-in-Original No.73/2024-GST (ADC) dated 30.11.2024
along with Form DRC-07 vide Ref.No.ZD330125064469C dated
08.01.2025 in the files of the Respondent and quash the same as
arbitrary, without jurisdiction and void
W.P.No.12084 of 2025:
MS/.Priya Petro Products
Represented by the proprietor, Mr.G. Ravi,
No. 123, SIDCO Industrial Estate, Vichoor,
Manali New Town, Chennai-600 103
... Petitioner
Vs.
The Assistant Commissioner
Ponneri Division Chennai Outer
Commissionerate, Mogappair,
Chennai-600 037.
... Respondents
Prayer:
Writ Petition filed under Article 226 of the Constitution of India
praying to issue a Writ of Certiorari, calling for the records on the file of
the respondent and to quash the impugned assessment order dated
29.08.2024 bearing DIN no. 20240859XL000000ADA5 passed by the
Respondent as arbitrary and thus render justice
W.P.No.12988 of 2025:
M/S.Meena Constructions
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W.P.No.29716 of 2024, etc., batch
Represented By Its Proprietor Mr. T. Anand
No. 4, Ellupakkam Village, Medur Post,
Ponneri, Thiruvallur 601 204
... Petitioner
Vs.
The Additional Commissioner of Central Tax
Chennai-outer, Newry Towers,
No. 2054-1, 2nd Avenue,
Anna Nagar, Chennai 600040.
... Respondents
Prayer:
Writ Petition filed under Article 226 of the Constitution of India
praying to issue a Writ of Certiorari, call for the records pertaining to the
impugned Order-in-Original No. 09/2025 and GST (ADC) in File No.
C.No.GEXCOM/ADJN/GST/ADC/1708/2024-ADJN dt. 31.01.2025
issued by the Respondent and quash the same
W.P.No.13600 of 2025:
M/S.Johnson Lifts Private Limited
Gstin 33aaacj0838q1zd,
Represented By Its Head - Taxation,
S.Vijayasubramanian,
No. 1, East Main Road,
Anna Nagar West Extension,
Chennai 600101
... Petitioner
Vs.
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W.P.No.29716 of 2024, etc., batch
1.The Joint Commissioner of CGST & Central Excise
Office Of The Commissioner Of Cgst & Central Excise,
Chennai North Commissionerate,
No.26/1 Mahatma Gandhi Road,
Chennai 600034.
2.The Joint Commissioner Of Cgst And Central Excise
Office Of The Commissioner Of Cgst And Central Excise
Audit I Commissionerate,
No.1, 1775, Jawaharlal Nehru Inner Ring Road,
Anna Nagar West Extension, Chennai 600101.
3.The Commissioner Of Cgst And Central Excise
Office Of The Commissioner Of Cgst And Central Excise,
Chennai North Commissionerate
No.26/1, Mahatma Gandhi Road,
Chennai 600034.
... Respondents
Prayer:
Writ Petition filed under Article 226 of the Constitution of India
praying to issue a Writ of Certiorari, call for the records pertaining to the
impugned order in original 124/2025 CH.N (JC) (GST) dated 26.2.2025,
issued by the 1st Respondent and quash the same
W.P.No.13959 of 2025:
Tvl Suzlon Energy Ltd
Rep by its Authorized Signatory
Kuman Vaghasiya
104, Delta Wing, 177, Anna Salai,
Chennai 600 002
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W.P.No.29716 of 2024, etc., batch
... Petitioner
Vs.
The Joint Commissioner of CGST and Central Excise
Chennai North Commissionerate, Chennai
... Respondents
Prayer:
Writ Petition filed under Article 226 of the Constitution of India
praying to issue a Writ of Certiorari, calling for Respondent In Original
No 123/25 CH.N.(JS)(GST) Order dated 26.02.2025 and quash the same
W.P.No.14805 of 2025:
M/S.Pachaiyappas Silks
Represented by its Proprietor
Mr Pachaiyappan Thandavamoorthy
No 348 Kanchipuram Chengalpattu Road,
Sri Ragavendra Readymade Matching Centre,
Ennaikaran, Kancheepuram-631 501
... Petitioner
Vs.
The Joint Commissioner Of Central Tax
Gst And Central Excise Appeal Ii
Commissionerate Newry Tower,
12th Main Road, Anna Nagar,
Chennai-600 040.
... Respondents
Prayer:
Writ Petition filed under Article 226 of the Constitution of India
praying to issue a Writ of Certiorari, calling for the records on the file of
16/69
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W.P.No.29716 of 2024, etc., batch
the Respondent and quash the impugned Order in Original No. 18/2025
GST JC dated 03.02.2025 passed u/s 74 of the CGST Act, 2017/TN GST
Act, 2017 Passed by the Respondent
W.P.No.15215 of 2025:
Pachaiyappas Readymades
Represented by its Proprietor
Mr. T.Sundarganesh
No.167, Gandhi road,
Kanchipuram Chengalpattu Road,
Ennaikaran, Kancheepuram
... Petitioner
Vs.
The Assistant Commissioner of GST and
Central Excise
Represented by its Proprietor
Mr. T.Sundarganesh
No.167, Gandhi road, Kanchipuram
Chengalpattu Road,
Ennaikaran, Kancheepuram
... Respondents
Prayer:
Writ Petition filed under Article 226 of the Constitution of India
praying to issue a Writ of Certiorari, calling for the records on the file of
the Respondent and quash the impugned Order in Original No. 07/2025-
AC/DC-GST dated 21.01.2025 passed u/s 74 of the CGST Act, 2017/TN
GST Act, 2017 Passed by the Respondent and pass such further other
orders as this Honourable Court
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W.P.No.29716 of 2024, etc., batch
W.P.No.15499 of 2025:
Madhuvanthi Consolidated Constructions
Private Limited
Represented by Its Director Mr.Raghuram H
A Block, No.7/490, 58th Street,
SIDCO Nagar, Villivakkam,
Chennai 600 049.
... Petitioner
Vs.
1.The Assistant Commissioner
Office Of The Assistant Commissioner Of
Central Excise And Gst Anna Nagar Division,
Newry Towers, No.2054-i, Ii Avenue,
Anna Nagar, Chennai-600 040
2.The Deputy Commissioner
Circle VII, Audit I Commissionerate,
Office of Commissioner of GST and Central Excise
No,1775, Jawaharlal Nehru Inner Ring Road,
Anna Nagar West Extension
Chennai 600 101.
3.The Superintendent of Central tax
Range III Anna Nagar Division
No.2054, I Block, II Avenue,
12th Main Road, Anna. Nagar,
Chennai 600 040.
... Respondents
Prayer:
Writ Petition filed under Article 226 of the Constitution of India
praying to issue a Writ of Certiorari, calling for the records of the
impugned Order-in-Original No.01/2025 and GST dated 09.01.2025
18/69
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W.P.No.29716 of 2024, etc., batch
along with Form DRC-07 vide Ref. No. ZD330125180134U dated
22.01.2025 in the files of the first respondent and quash the same as
arbitrary, without jurisdiction and void
W.P.No.16111 of 2025:
M/S.Srinivasan Prasanna
Trade Name K B Enterprises
represented by its Proprietor
No. 11, 48th street, Nanganallur,
Chennai -600 061
... Petitioner
Vs.
1.Superintendent of GST and Central Excise
Range II ALANDUR Division Office of the
Superintendent Of CGST AND Central Excise
Alandur- II Range chennai South
Commissionerate First Floor ,
M.H.U. Complex, 692 Anna Salai,
Nandanam, Chennai -035.
2.Commercial Tax officer
Nanagnallur Assessment Circle,
Chennai South III- Tamil Nadu.
... Respondents
Prayer:
Writ Petition filed under Article 226 of the Constitution of India
praying to issue a Writ of Certiorari, calling for the records of Order in
Original No.14/2025-GST (Supdt-R II) dated 04.02.2025 passed by the
1st respondent and to quash the same and further direct the 1st
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W.P.No.29716 of 2024, etc., batch
respondent to pass fresh assessment after granting an opportunity of
personal hearing to the petitioner
W.P.No.16840 of 2025:
M/s. Sab Charge
Represented by its Proprietor
Mr Saurabh Gupta
Tower No 24, Flat No 404,
North Town Apartments,
Perambur, Binny Garden,
Chennai-600 012
... Petitioner
Vs.
The Principal Commissioner Of Goods And
Service Tax And Central Excise,
Chennai North Commissionerate,
No.26/1, Mahatma Gandhi Road,
Chennai-600034.
... Respondents
Prayer:
Writ Petition filed under Article 226 of the Constitution of India
praying to issue a Writ of Certiorari, Calling for Respondent Order in
Original dated 28.01.2025 with Ref. No. No.42/2025-GST CH.N (JC)
and quash the same
W.P.Nos.16845 & 16852 of 2025:
M/s PVP Ventures Limited
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W.P.No.29716 of 2024, etc., batch
Represented by its Authorized Signatory
Mr. Anand Kumar
9th Floor, Door No. 2, KRM Centre,
Harrington Road, Chetpet, Chennai-600031 .
... Petitioner
Vs.
1.The Senior Intelligence Officer
Directorate General of Goods and Service Tax
Intelligence, Hyderabad Zonal unit,
Block B, Kavuri Hills, Guttala Begumpet,
Madhapur, Hyderabad- 500 033.
2.The Additional Director
Directorate General of Goods and Service Tax Intelligence,
Hyderabad Zonal Unit, Block B, Kavuri Hills,
Guttala Begumpet, Madhapur,
Hyderabad-500033
3.The Joint Commissioner
Office of the Principal Commissioner of
CGST and Central Excise Chennai North
Commissionerate
No. 26/1, Mahatma Gandhi Road,
Chennai-600034
... Respondents
Prayer:
Writ Petition filed under Article 226 of the Constitution of India
praying to issue a Writ of Certiorari, Calling for the records relating to
the Impugned Show Cause Notice No. 41/2024-25-GST from F. No.
INV/DGGI/HZU/GST/34/2020-21 (OR No.37/2024-25-GST) bearing
DIN.202407DSS40000999DB3 dated 22.07.2024 issued by the 2nd
Respondent and quash the same
21/69
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W.P.No.29716 of 2024, etc., batch
calling for the records relating to the Order-in-Original No.
08/2025 GST CHN JC bearing C. No. GEXCOM/ADJN/GST/ADC/
1312/2024 and DIN 20250159TK0000812563 dated 17.01.2025 passed
the 3rd Respondent and quash the same
W.P.No.19849 of 2025:
Golden Rocks
Rep. By Its Proprietor -a, Suresh Kumar,
1/36-2, Kundumarannapalli Village,
Denkanikottai Taluk-635113.1/36-2,
Kundumaranapalli Village,
Denkanikottai Taluk
... Petitioner
Vs.
Additional Commissioner,
Office Of The Commissioner Of Goods And
Service Tax And Central Excise, Gst Bhawan,
No.1, Foulkes Compound, Anaimedu,
Salem-636001.
... Respondents
Prayer:
Writ Petition filed under Article 226 of the Constitution of India
praying to issue a Writ of Certiorari, calling for Respondent Order in
Original dated 03.02.2025 with Sl. No. 27/2025-GST (ADC) in so far as
the petitioner is concerned and quash the same
W.P.No.19857 of 2025:
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W.P.No.29716 of 2024, etc., batch
Hosur Builders
GSTIn 33ANQPR1123G1Z4,
Rep by its Proprietor Rajeshwari
54, 1st Floor, Sowripalayam Road,
Puliakulam, Coimbatore 641 0451.
... Petitioner
Vs.
1.The Assistant Commissioner of GST and
Central Excise
Office of the Principal Commissioner of GST
and Centra Excise, No 6/7, ATD street,
Race course, Coimbatore 641 018
2.The Assistant/Deputy Commissioner of GST
and Central Excise, Coimbatore III Division
Aadithya Towers, Trichy Road,
Ramanathapuram, Coimbatore 641 045
... Respondents
Prayer:
Writ Petition filed under Article 226 of the Constitution of India
praying to issue a Writ of Certiorari, call for the records pertaining to the
impugned Show Cause Notice No. 12/2024-25 GST (AE) dated
26.3.2025 issued by the First Respondent and quash the same
W.P.No.19861 of 2025:
Smart Granite
Rep by its Proprietor A Suresh Kumar
Survey No. 206/1F, Shoolagiri,
Dinnur Addakurukki,
Krishnagiri-635 130
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W.P.No.29716 of 2024, etc., batch
... Petitioner
Vs.
Additional Commissioner, Salem
Office Of The Commissioner Of Goods And
Service Tax And Central Excise,
Gst Bhawan, No.1, Foulkes Compound,
Anaimedu, Salem-636 001
... Respondents
Prayer:
Writ Petition filed under Article 226 of the Constitution of India
praying to issue a Writ of Certiorari, calling for Respondent Order in
Original dated 03.02.2025 with Ref. No. 27/2025-GST (ADC) in so far
as the petitioner is concerned and quash the same
W.P.No.20367 of 2025:
M/S.Pachaiyappas Silks Private Limited
Rep by its Managing Director
Pachiayappan Thandavamurthy
No.167, Gandhi Road,
Kanchipuram Chengalpattu Road,
Tamil Nadu- 631501
... Petitioner
Vs.
The Joint Commissioner of Central Tax
Commissioner of GST and Central Excise
Newry Tower . No.2054- I. II Avenue,
anna nagar, Chennai -40.
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... Respondents
Prayer:
Writ Petition filed under Article 226 of the Constitution of India
praying to issue a Writ of Certiorari, calling for the records on the file of
the Respondent and quash the impugned Order in Original No. 60/2025-
GST (JC) dated 13.05.2025 passed u/s 74 of the CGST Act, 2017/TN
GST Act, 2017 by the Respondent
W.P.No.22277 of 2025:
Young Women s Christian Association of
Madras
REP BY AUTHORISED SIGNATORY MRS.
E.B VITHIYA PADMINI
No.1086 Poonamalle High Road Chennai
... Petitioner
Vs.
The Deputy Commissioner
Purasaiwakam Division,
Chennai North Commissioerate,
No. 2054 I Block Ii Avenue,
12th Main Road, Anna Nagar,
Chennai 040.
... Respondents
Prayer:
Writ Petition filed under Article 226 of the Constitution of India
praying to issue a Writ of Certiorari, calling for the records on the file of
the respondent and to quash the impugned assessment order dated
28.11.2023 bearing order in original no.116/2023 also bearing DIN no.
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W.P.No.29716 of 2024, etc., batch
20231159TK00-00291118 passed by the Respondent as arbitrary.
W.P.No.22281 of 2025:
A Suresh Kumar
S/O Mr. Angappan,
NO.. 280 Venkatesh Nagar
Alasantham Hosur 635 109
... Petitioner
Vs.
Additional Commissioner salem
Office of the Commissioner of Goods and
Service Tax and Central Excise,
GSt Bhawan No 1, Foulkes Compound,
Anaimedu, Salem 636 001
... Respondents
Prayer:
Writ Petition filed under Article 226 of the Constitution of India
praying to issue a Writ of Certiorari, calling for Respondent Order in
Original in Sl No 27/2025-GST (ADC) dated 03.02.2025 in so far as the
petitioner is concerned and quash the same
W.P.No.22808 of 2025:
M/s United Pharma
Rep. by its Managing Partner
No. 57, Louis Pragasam Street,
Puducherry - 605001
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W.P.No.29716 of 2024, etc., batch
... Petitioner
Vs.
1.The Superintendent of GST and Central
Excise
Office of the Superintednet of GST and
Cenral Exise, Range 1 B, Puducherry,
No 48/1, Second Floor Azeez Nagar,
Reddiyarpalayam Puducherry 605 010
2.Additional Commissioner Appeals I
Office of the Commissioner of GST and
Central Excise (Appeals-I)
26 1, Mahatma Gandhi Road,
Nungambakkam, Chennai - 600034
... Respondents
Prayer:
Writ Petition filed under Article 226 of the Constitution of India
praying to issue a Writ of Certiorari, call for the records in the
proceedings of the Respondent in Order in Original No.21/2023 (Supdt-
1B)-GST dated 26.12.2023 passed by the 1st Respondent and the
Consequential Order in Appeal No.50/2025 (GSTA-1) (ADC) dated
20.02.2025 passed by the 2nd Respondent and to quash the same as
arbitrary and illegal
For Petitioner : Mr.G.Derrick Sam
in W.P.Nos.29716, 29726 & 29720/2024,
12988, 13600 & 19857 of 2025
Mr.V.Srikanth
in W.P.No.34134 of 2024
Mr.A.Abdul Hameed, Sr.counsel
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W.P.No.29716 of 2024, etc., batch
for Ms.S.Mekhala,
in WP.No.2270 & 3597 of 2025
Mr.M.A.Mudimannan
in WP.Nos.7616 & 7646 of 2025
Mr.C.Ramkumar, in W.P.No.7644 of 2025
Mr.I.Dinesh in W.P.No.7766 of 2025
Mr.Srinath Sridevan, Sr.counsel,
for Mr.Adithya Reddy,
in W.P.Nos.9000, 9001 & 13959 of 2025
Mr.M.Narasimha Bharathi
in W.P.Nos.9100 & 15499 of 2025
Mr.J.Ashish, in WP.Nos.12084 & 22277/2025
Ms.Vandana Vyas, in W.P.No.14805 of 2025
Ms.V.Anumitha in W.P.No.15215 of 2025
Mr.R.Ganesh Kanna in WP.No.16111/2025
Mr.Adithya Reddy
in WP.No.16840, 19849, 19861 & 22281/2025
Mr.P.V.Balasubramaniam, Sr.counsel,
for Mr.Harish Bindumadhavan,
in W.P.Nos.16845 & 16852 of 2025
Ms.B.R.Varshini in W.P.No.20367 of 2025
Mr.Joseph Prabakar, in WP.No.22808 of 2025
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W.P.No.29716 of 2024, etc., batch
For Respondents : Mr.AR.L.Sundaresan,
Additional Solicitor General
Assisted by
Ms.Revathi Manivannan,
Sr.St.counsel in W.P.No.22281 of 2025
& Mr.R.P.Pragadish, Sr.St.counsel
& Mr.J.Nalinidhar, JPC,
in WP.Nos.29716, 29720 & 29726 of 2024
for R1 to R4 in WP.No.22808/2025
for R2 to R4 in W.P.No.3597 of
Mr.Rajnish Pathiyil, SPC in WP.No.34137/24
Mr.K.S.Ramaswamy, Sr.St.counsel
& Mr.J.Vasu, Jr.St.counsel
in WP.No.2270 of 2025
Mr.C.Harsha Raj, SGP,
for R5 in W.P.No.3597 of 2025
& for R2 in WP.No.16111 of 2025
Mr.Sai Srujan Tayi, SPC,
& Ms.Pooja Jain, JPC,
in WP.Nos.7616, 7646, 7766, 9000, 9001,
& 14805 of 2025 & 20367 of 2025
Mr.K.S.Ramaswamy, Sr.St.counsel,
in W.P.No.7644 of 2025
Mr.B.Ramanakumar, Sr.St.counsel
in W.P.No.9100 & 13600 of 2025
Mr.Su.Srinivasan, SPC,
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W.P.No.29716 of 2024, etc., batch
& Mr.T.Nalinidhar, JPC
in WP.No.12084 of 2025
Mr.A.P.Srinivas, Sr.St.counsel
in W.P.Nos.12988, 17239 of 2025
& for R1 in W.P.No.16111 of 2025
Mr.S.M.Deenadayalan, Sr.St.counsel,
in W.P.No.13959, 16840, 16845 & 16852/25
Mr.Rajnish Pathiyil, SPC,
& Mr.B.Sivaraman, JPC,
in W.P.Nos.15215 & 15499 of 2025
Mr.S.Gurumoorthy, Sr.St.counsel,
& Mr.G.Meganathan, Jr.St.counsel,
in W.P.Nos.19849, 19857 & 19861 of 2025
Mr.Rajendran Raghavan, Sr.St.counsel,
in W.P.No.22277 of 2025
Mr.Sathyam, ACGSC, for R1
in W.P.No.3597 of 2025
COMMON ORDER
All these writ petitions have been filed challenging the issue with
regard to the “bunching of Show Cause notices”, i.e., issuance of a
single show cause notice, by the respondents, for more than one financial
year.
2. As the issue involved in all these Writ Petitions is identical in
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nature and the relief sought thereunder is interconnected, they were
heard together and disposed of vide this Common Order.
3. Petitioners’ submissions:
3.1 Mr.Abdul Hameed, Mr.Srinath Sridevan &
Mr.P.V.Balasubramaniam, learned Senior counsel and Mr.G.Natarajan &
Mr.Joseph Prabakar, learned counsel had appeared for the respective
petitioners.
3.2 The learned Senior counsel appearing for the respective
petitioners would submit that the bunching of Show Cause notice for
more than one financial year is bad in law and against the principles of
natural justice and also it will prejudice the interest of an assessee.
3.3 Further, they would submit that the Good and Services Tax
Act, 2017, (hereinafter called as “GST Act”) fixes the limitation for
issuance of notices and passing the assessment orders for each and every
financial years under section 73 and 74 of the GST Act. When such
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W.P.No.29716 of 2024, etc., batchbeing the case, the notice under said Sections shall be issued to the
Assessee separately for each financial year. Hence, they would contend
that the bunching of notice for more than one financial year is against
the spirit of section 73 and 74 of GST Act.
3.4 They would also submit that while bunching, the show cause
notices were issued at the fake end of the limitation period, due to
which, the petitioner may not be able to collect the evidences within
time. For example, if there is bunching of show cause notices for more
than one financial years, viz, 2017-18 to 2022-23, the said notice will be
issued 3 moths prior to the end of limitation of the 1 st financial year, i.e.,
2017-18. In such case, though the limitation is very much available for
the subsequent financial years, viz., 2018-19 to 2022-23, the petitioners
were forced to file their replies for the said notice at the very fake end of
limitation. Under these circumstances, the petitioners were unable to
collect all the relevant documents to substantiate their cases, which
causes unnecessary hardships to the petitioners.
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3.5 When a single assessment order is passed for more than one
financial years, the Assessee will also face the following hardships:
i) The petitioners will not be able to file an
application for compounding of offences, under Section
138 of GST Act, for any particular financial year.
ii) If the respondent introduced the Amnesty
Scheme for any one or two financial years, the petitioner
cannot avail the said Scheme without paying the amount
demanded by the respondent for all the financial years
included in the notice/order.
iii) If the petitioner is intend to contest the issue
pertaining to one or two years and is willing to remit the
tax amount for remaining years, the bunching of
notices/orders will create unnecessary hurdles for the
petitioner in both contesting and settling the issues
pertaining to any particular financial year.
3.6 Therefore, they would contend that the bunching of
notices/orders will only pave way for unnecessary hardships to the
assessee. On the other hand, there will be no difficulties for the
respondent to issue separate show cause notices for each financial year
as prescribed under Sections 73 & 74 of the GST Act.
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3.7 By referring Sections 73 & 74 of the GST Act, they would
submit that in terms of the provisions of Section 73(1) and 74(1) of GST
Act, initially, the respondent shall issue the show cause notice for any
one financial year or any one tax period and if there is any similar issue
for the subsequent years/tax period, as per Sections 73(3)&(4) &
74(3)&(4) of GST Act, it is mandatory for the respondent to issue
independent statements for each and every tax periods. In terms of
Section 73(4) & 74(4), the said statement shall deemed to be a notice
issued under Section 73(1) & 74(1) of GST Act respectively. Therefore,
according to the petitioners, the first notice has to be a single notice and
the subsequent notices for similar issue shall be issued by way of
independent statements for each and every tax period. Hence, they would
submit that there is a clear prohibition for issuance of notice for more
than one financial year based on the filing of annual returns.
3.8 By referring Section 73(2)(3) & (10) and 74(2)(3) & (10) of
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GST Act, they would submit that the orders shall be passed within a
period of 3 years or 5 years respectively from the due date for furnishing
annual returns for the financial year, for which tax was not paid or short
paid or erroneously refunded or input tax credit wrongly availed or
utilised. Therefore, they would submit that independent notices have to
be issued for each and every financial years, otherwise, the interest of
the petitioners would be prejudicially affected. Further, they would
contend that the bunching of show cause notices/orders is bad in law. In
this regard, they had referred to the judgement of this Court in Titan
Company Ltd., vs. Joint Commissioner of GST & Central Excise
reported in (2024) 15 Centax 118 (Mad.), wherein it has been held that
bunching of notices is impermissible.
3.9 Further by referring judgement dated 21.03.2025 rendered in
W.A.Nos.2389 & 1397 of 2024, which was filed challenging the
aforesaid Titan judgement, he would submit that based on the agreement
of the parties, the said appeal was decided, wherein it was directed that
the assessment orders have to be passed by the Department for each
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W.P.No.29716 of 2024, etc., batch
assessment years independently with a gap of minimum 4 weeks.
3.10 They had also referred the following judgements in support
of their contentions:
(i) M/s.Bangalore Gold Club vs. Assistant
Commissioner of Commercial Taxes (Enforcement)
reported in 2024-VIL-1023-KAR;
(ii) M/s.Veremax Technologie Services Limited
vs. The Assistant Commissioner of Central Tax reported
in 2024-VIL-1028-KAR;
(iii) M/s.Tharayil Medicals vs. The Deputy
Commissioner and another reported in 2025-VIL-356-
KER;
(iv) Ghanshyam Das vs. Regional Assistant
Commissioner of Sales Tax, Nagpur reported in
MANU/SC/0216/1963;
(V) Kamalammal vs. Board of Revenue by the
Commissioner of Commercial Taxes, Madras and
another reported in 1963 SCC OnLine Mad 307;
(vi) Shyama Charan Shukla vs. The State of
Madhya Pradesh and others reported in
MANU/MP/0051/1974;
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3.11 Therefore, they prayed this Court to quash all the show cause
notices issued by the respondent since the same are unsustainable in law.
4. Respondents’ submissions:
4.1 Per Contra, Mr.AR.L.Sundaresan, learned Additional Solicitor
General appearing for the respondents has strongly opposed the
contentions made by the petitioners and would submit that in terms of
Sections 73 & 74 of the GST Act, there is no prohibition or specific bar
to issue a single show cause notice for more than one financial year. In
absence of such prohibition/bar, the respondents can issue a single show
cause notice for more than one financial year and hence, there is no
merits in the submissions made by the petitioners.
4.2 Further, by referring Sections 73 & 74 of the GST Act, he
would submit that in the provisions of the said Sections, it has been
stated as “any period”, which means, the issuance of notice shall be for
any block of years and the same is not constrained to a single year.
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Therefore, he would contend that it is not proper for the petitioner to
state that the show cause notices have to be issued separately for each
financial years.
4.3 He would also contend that the word “tax periods” mentioned
in Section 73(4) & 74(4) of GST Act, includes not only the year-wise tax
periods but also the month-wise tax periods. Obviously, there will be 12
tax periods in one financial year. Therefore, if the case of the petitioners
is accepted by this Court, then the respondents will have to issue 12
notices for each tax period in one financial year and they cannot club the
same. On the other hand, he would submit that when the petitioner had
accepted the clubbing of show cause notices for the 12 month-wise tax
periods, as state above, there will not be any difficulties in accepting the
show cause notice, which was clubbed and issued for more than one
financial year, within the period of limitation. Therefore, he would
contend that there is no substance in the submissions made by the
petitioners and hence, he prays for dismissal of these petitions.
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5. I have given due consideration to the submissions made by all
the respective learned Senior counsel appearing for the petitioners and
the learned Additional Solicitor General appearing for the respondents
and also perused the materials available on record.
6. In the cases on hand, the only issue that has to be decided is as
to whether the respondents can issue single show cause notice for more
than one financial year ?
7. Now, let me examine the provisions of Sections 73 & 74 of the
GST Act, which deals with regard to the issuance of show cause notice.
Hence, it would be apposite to extract the relevant portions of Sections
73 & 74 of the GST Act, which read as follows:
“73. Determination of tax not paid or short paid
or erroneously refunded or input tax credit wrongly
availed or utilised for any reason other than fraud or
any willful-misstatement or suppression of facts.—
(1) Where it appears to the proper officer that any
tax has not been paid or short paid or erroneously
refunded, or where input tax credit has been wrongly39/69
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W.P.No.29716 of 2024, etc., batchavailed or utilised for any reason, other than the reason
of fraud or any wilful-misstatement or suppression of
facts to evade tax, he shall serve notice on the person
chargeable with tax which has not been so paid or
which has been so short paid or to whom the refund has
erroneously been made, or who has wrongly availed or
utilised input tax credit, requiring him to show cause as
to why he should not pay the amount specified in the
notice along with interest payable thereon under section
50 and a penalty leviable under the provisions of this
Act or the rules made thereunder.
(2) The proper officer shall issue the notice under
sub-section (1) at least three months prior to the time
limit specified in sub-section (10) for issuance of order.
(3) Where a notice has been issued for any period
under sub-section (1), the proper officer may serve a
statement, containing the details of tax not paid or short
paid or erroneously refunded or input tax credit wrongly
availed or utilised for such periods other than those
covered under sub-section (1), on the person chargeable
with tax.
(4) The service of such statement shall be deemed
to be service of notice on such person under sub-section
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(1), subject to the condition that the grounds relied upon
for such tax periods other than those covered under sub-
section (1) are the same as are mentioned in the earlier
notice.
(5) to (8) …………………..
(9) The proper officer shall, after considering the
representation, if any, made by person chargeable with
tax, determine the amount of tax, interest and a penalty
equivalent to ten per cent. of tax or ten thousand rupees,
whichever is higher, due from such person and issue an
order.
(10) The proper officer shall issue the order under
sub-section (9) within three years from the due date for
furnishing of annual return for the financial year to
which the tax not paid or short paid or input tax credit
wrongly availed or utilised relates to or within three
years from the date of erroneous refund.
74. Determination of tax not paid or short paid
or erroneously refunded or input tax credit wrongly
availed or utilised by reason of fraud or any willful
misstatement or suppression of facts.—
(1) Where it appears to the proper officer that any
tax has not been paid or short paid or erroneously
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refunded or where input tax credit has been wrongly
availed or utilised by reason of fraud, or any wilful-
misstatement or suppression of facts to evade tax, he
shall serve notice on the person chargeable with tax
which has not been so paid or which has been so short
paid or to whom the refund has erroneously been made,
or who has wrongly availed or utilised input tax credit,
requiring him to show cause as to why he should not pay
the amount specified in the notice along with interest
payable thereon under section 50 and a penalty
equivalent to the tax specified in the notice.
(2) The proper officer shall issue the notice under
sub-section (1) at least six months prior to the time limit
specified in sub-section (10) for issuance of order.
(3) Where a notice has been issued for any period
under sub-section (1), the proper officer may serve a
statement, containing the details of tax not paid or short
paid or erroneously refunded or input tax credit wrongly
availed or utilised for such periods other than those
covered under sub-section (1), on the person chargeable
with tax.
(4) The service of statement under sub-section (3)
shall be deemed to be service of notice under sub-
section (1) of section 73, subject to the condition that the
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grounds relied upon in the said statement, except the
ground of fraud, or any wilful-misstatement or
suppression of facts to evade tax, for periods other than
those covered under subsection (1) are the same as are
mentioned in the earlier notice.
(5) to (8) ……………..
(9) The proper officer shall, after considering the
representation, if any, made by the person chargeable
with tax, determine the amount of tax, interest and
penalty due from such person and issue an order.
(10) The proper officer shall issue the order under
sub-section (9) within a periodof five yearsfrom the due
date for furnishing of annual return for the financial
year to which the tax not paid or short paid or input tax
credit wrongly availed or utilised relates to or within
five years from the date of erroneous refund.
8. A reading of above provisions shows that the respondents shall
serve notice, in terms of sub-section (1) of Section 73/74 of the GST
Act, on the person chargeable with tax, which has not been paid, etc.,
requiring him to show cause as to why he should not pay the amount
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specified in the notice, along with the interest and penalty, for various
situations mentioned therein.
9. The provisions of Sections 73(1)/74(1) of GST Act deals with
the aspect of issuance of show cause notice in any particular situation,
whereas, in Section 73(2)/74(2) of GST Act, it has been stated that the
proper officer shall issue notice under Sub-Section (1) atleast three/six
months prior to the time limit fixed under Sections 73(10)/74(10) of the
GST Act for issuance of order. While reading the provisions of Sections
73(10)/74(10) of GST Act, it reveals that the time limit for passing
assessment order is up to three/five years from the last date for filing the
annual return of the relevant financial year.
10. Further, Section 73(3)/74(3) of GST Act would state that “if a
notice has been issued for any period under sub-section (1), the proper
officer may serve a statement, containing the details of tax not paid,
short paid or erroneously refunded or input tax credit wrongly availed or
utilised for such periods other than those covered under sub-section (1)
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on the person chargeable with tax”, which means a statement is required
to be served to the subsequent tax periods and the issuance of such
statement shall deemed to be a notice under Section 73(1)/74(1) of the
GST Act. Thus, it is clear that at first instance, the notice shall be issued,
under Section 73(1)/74(1), for a tax period, based on filing of either
monthly return or annual return. If the notice was issued based on annual
return, it could be for any tax period within the relevant financial year
but at any cost, it should not be beyond the said relevant financial year.
Thus, when the Act mandates for issuance of notice in a particular
manner, the notice has to be issued accordingly. Therefore, there is a
clear bar for “bunching of show cause notice”, i.e., issuance of single
show cause notice for more than one financial year.
11. Section 73(10)/74(10) of the GST Act specifically provides
the time limit of 3 years/5 years from the last date for filing the annual
returns for the financial year to which the tax dues relates to. Thus, the
GST Act considered each and every financial year as separate unit, due
to which, the limitation has been fixed for each and every financial year
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separately. When such being the case, clubbing more than one financial
year, for the purpose of issuance of show cause notice, would not be
considered as in accordance with the provisions of Section 73/74 of the
GST Act. Therefore, the limitation period of 3 years/5 years would be
separately applicable for every financial year, thus, the limitation period
would vary from one financial year to other. It is not that the limitation
would be carried over or continuing in nature, so as to, club the financial
years together. For these reasons also, the bunching of show cause notice
is impermissible. In this regard, the Constitution Bench of the Hon’ble
Apex Court in the decision rendered, which was reported in AIR 1966
SC 1350 (State of Jammu and Kashmir and Others v. Caltex (India)
Ltd) has held as follows:
“where an assessment encompasses different
assessment years, each assessment year could be easily
split up and dissected and the items can be separated
and taxed for different periods.”
12. Section 73(3)/74(3) of the GST Act refers to issuance of
“statement”, for subsequent “tax periods”, containing the details of tax
liabilities pertaining to the respective tax periods. If a notice, under
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Section 73(1)/74(1) of the GST Act, is issued for any particular tax
period, a statement shall be issued, in terms of Section 73(3)/74(3) of
GST Act, for the subsequent months and the said statements shall
deemed to be a notice issued under Section 73(1)/74(1) of the GST Act.
13. In Section 73(3)/74(3) of the GST Act, it has been stated that
“Where a notice has been issued for any period under sub-section
(1)………” Therefore, an argument was made by the learned Additional
Solicitor General that “any period” means, the period, which may be
more than one financial year and hence, he raised a contention that the
notice under Section 73(1)/74(1) of the GST Act can be issued for more
than one financial year.
14. In Section 73(4)/74(4) of the GST Act, it has been stated as
follows:
“(4) The service of such statement shall be
deemed to be service of notice on such person under
sub-section (1), subject to the condition that the grounds
relied upon for such tax periods other than those
covered under sub-section (1) are the same as are
mentioned in the earlier notice.”47/69
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15. In the above provision, the word “tax period” has been
mentioned. In Section 73(1)(3)/74(1)(3) of GST Act, it has been
mentioned that notice can be issued for “any period”. Therefore, a
conjoint reading of Section 73(1)(3)&(4)/74(1)(3)&(4) makes it clear
that “any period” is nothing but the “tax period”. Thus, based on the “tax
period”, the show cause notice, under Section 73/74 of GST Act, can be
issued by the Department.
16. At this juncture, it would be apposite to extract the meaning
of the word “tax period” in terms of Section 2(106) of the GST Act,
which reads as follows:
“2(106) “tax period” means the period for which
the return is required to be furnished”
17. A reading of the above Section would show that “tax period”
means the period, for which, the return is required to be furnished.
Therefore, based on the filing of returns, the tax period will be
determined. In GST Law, an Assessee is required to file monthly return
as well as annual return. Therefore, based on the monthly return, notice,
under Section 73/74, can be issued, for any particular month. Likewise,
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based on the annual returns, notice, under Section 73/74, can be issued
for the entire financial year or otherwise, as decided by the department,
but not more than the relevant financial year.
18. Now, it would be apposite to extract the definition of the word
“return” in terms of Section 2(97) of the GST Act, which reads as
follows:
2(97) “return” means any return prescribed or
otherwise required to be furnished by or under this Act or
the rules made thereunder;
19. A reading of the above would show that the “return” is
prescribed by the Act or the Rules made thereunder. As stated above, an
Assessee is required to file monthly return as well as annual return and
issuance of show cause notice should be strictly based on the tax periods,
which is determined based on filing of returns. Therefore, it is clear that
the show cause notice can be issued either based on the monthly return
or based on the annual return for the entire financial year or part thereof
as decided by the Department. If any return is filed for more than one
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financial year, then, based on the said returns, single show cause notice
can be issued. However, under the GST Law, there is no requirement for
filing any returns other than monthly and yearly returns. Hence, no show
cause notice could be issued for more than one financial year.
20. In view of the above, there is no doubt that in terms of GST
Law, “any period”, for the purpose of issuance of show cause notice,
includes, “monthly tax period” or “yearly tax period” and the GST Act
will not permit for issuance of show cause notice beyond such period,
i.e., no show cause notice can be issued for the period of more than one
financial year.
21. Therefore, as discussed above, a conjoint reading of the word
“tax period”, as defined in Section 2(106) of GST Act, along with the
provisions of Section 73(1),(2),(3),(4),(10)/74(1),(2),(3),(4),(10) of GST
Act, makes it very clear that there is a specific bar in terms of the Section
73/74 for “bunching of show cause notice”, i.e., no show cause notice
can be issued for more than one financial year.
22. While examining Section 128 of GST Act, which deals with
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“the power to waive penalty or fee or both”, it is clear that the
Government may introduce any Scheme, by way of notification, to
waive, in part or full, any penalty. In such case, if a show cause notice
was issued, prior to the date of such notification, by clubbing more than
one financial year, the petitioners will be forced to pay the tax amount
for all the financial years included in the said notice for availing the
aforesaid Scheme introduced by the Central Government. Hence, it will
create a great hardships to the petitioners.
23. A similar hardship will be faced by the petitioners, when they
intend to file an application for compounding the offences under Section
138 of the GST Act for any particular or couple of years.
24. Further, though the petitioners have very good case to contest
for any particular tax period, they will not be able to do so since the
notice was issued and accordingly, orders were passed by the respondent
by clubbing more than one financial year. Hence, the rights of the
petitioners, to file an appeal against the assessment order, will get
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prejudicially affected.
25. That apart, when a notice was issued and order was passed
under Section 74 of the GST Act by clubbing more than one financial
year, where the case was made out for any particular tax period and there
is a scope to set aside the said order for remaining tax period, the
petitioners’ right to contest the matter pertaining to any particular tax
period under Section 73 of the GST Act will get affected since the
Department will look into the said matter from the perspective of
commission of offence under Section 74 of the GST Act for all the years
mentioned in the notice when it was intact committed only particular
financial year.
26. In a similar situation, this Court has already held that the
bunching of show cause notice is impermissible vide order passed in
Titan case, wherein, it has been stated as follows:
“13.The main contention of the petitioner was that
bunching of show cause notices was not allowed in law
and it is against the provisions of Section 73 of the Act.
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W.P.No.29716 of 2024, etc., batchSection 73(10) of the Act specifically provides a time
limit of three years from the due date for furnishing of
annual return for the financial year to which the tax due
relates to. In the present case, notice was issued under
Section 73 of the Act for determination of the tax and
therefore, the limitation period of three years as
prescribed under Section 73(10) would be applicable.
Therefore, the contention of the respondent that there is
no time limit contemplated under Section 73 of the Act is
not correct.
14.Further, by issuing bunching of show cause
notices for five Assessment Years starting from 2017-18
to 2021-22, the respondents are trying to do certain
things indirectly which they are not permitted to do
directly and the same is not permissible in law. If the
law states that a particular action has to be completed
within a particular year, the same has to be carried out
accordingly. The limitation period of three years would
be separately applicable for every assessment year and
it would vary from one assessment year to another. It is
not that it would be carried over or that the limitation
would be continuing in nature and the same can be
clubbed. The limitation period of three years starts from53/69
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W.P.No.29716 of 2024, etc., batchthe date of furnishing of the annual return for the
particular financial year.
15.Therefore, issuing bunching of show cause
notices is against the spirit of provisions of Section 73 of
the Act and the Constitution Bench of the Hon’ble Apex
Court in the decision reported in AIR 1966 SC 1350,
State of Jammu and Kashmir and Others v. Caltex
(India) Ltd has held that where an assessment
encompasses different assessment years, each
assessment year could be easily split up and dissected
and the items can be separated and taxed for different
periods. The said law was laid down keeping in mind
that each and every Assessment Year will have a
separate period of limitation and the limitation will start
independently and that is the reason why the Hon’ble
Supreme Court has held that each assessment year
could be easily split up and dissected and the items can
be separated and taxed for different periods. The said
principle would apply to the present case as well.
16.For all these reasons, I do not find force in the
submission made by the learned Senior Standing
Counsel appearing on behalf of the respondents.
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Therefore, I find fault in the process of issuing of
bunching of show cause notices and the same is liable to
be quashed.”
27. Further, in the judgement rendered in M/s.Tharayil Medicals
case by the Hon’ble Division Bench of Kerala High Court, it has been
stated as follows:
“11. When we read sub-sections (9) and (10) of
Section 74, which specifically refer to “ financial year to
which the tax not paid or short paid or input tax wrongly
availed or utilised relates” while passing the final order
of adjudication, it presupposes that independent show
cause notice be issued to the assessee for each different
years of assessment while proceeding under Section 74.
We are constrained to hold so because, as we noted
earlier, the assessee can raise a distinct and independent
defence to the show cause notice issued in respect of
different assessment years. In other words, the
entitlement to proceed and assess each year being
separate and distinct, and further the time limit being
prescribed under the Statute for each assessment year
being distinct, we see no reason as to why we should not55/69
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W.P.No.29716 of 2024, etc., batchhold that separate show cause notices are required
before proceeding to assess the assessee for different
years of assessment under Section 74.
12. There is yet another reason why we should
hold that separate show-cause notices are issued for
different assessment years. There may be cases where
proceedings are initiated in the guise of a show cause
notice under Section 74 wherein, on facts, the case of the
assessee will fall under Section 73 of the CGST/SGST
Act. We find that insofar as the time limit prescribed
under Section 73(10) of the CGST/SGST Act is
concerned, it is three years instead of five years and
further, the aspect of fraud, willful misstatement and
suppression do not arise for consideration in56/69
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W.P.No.29716 of 2024, etc., batchproceedings under Section 73. Thus, by issuing a
composite notice, the assessing authority, cannot bypass
the mandatory requirement of Section 73 to complete the
assessment by falling back on a larger period of
limitation under sub-section (10) of Section 74. If such a
recourse is permitted, then certainly the said action
would be a colourable exercise of the power conferred by
the statute and will offend express provisions of the
CGST/SGST Act qua limitation. This reason would also
prompt us to hold that in cases where the assessing
officer finds that an assessee is liable to be proceeded
either under Section 73 or under Section 74 for different
assessment years, a separate show cause notice has to be
issued. Still further, since proper officer need to issue a
show cause notice prior to 6 months to the time limit
prescribed under sub-section (10) of Section 74, if a
composite notice is issued, the assessee will be
prejudiced inasmuch as the availability of a lesser period
to submit a proper and meaningful explanation. This also
is a strong indicative factor which would prompt us to
hold in favour of the assessee.
13. We find normally a writ petition against the
show cause notice is not to be entertained by the writ57/69
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W.P.No.29716 of 2024, etc., batchcourt as held by us in Deputy Commissioner of
Intelligence v. Minimol Sabu (W.A. No.238 of 2025), we
have carved out the exceptions like in a case where a
total lack of inherent jurisdiction being in issuance of
show cause notice under Section 74 of the CGST/SGST
Act. In such circumstances, the writ petitioner need not
be relegated to the alternative remedy by way of appeal.
14. In the present case, we find that since the
challenge to the show cause notice goes to the root of the
jurisdiction of the proper officer in issuing the same and
we hold that the writ petition is perfectly maintainable”
28. In view of the above discussion, this Court pass the following
orders:
(i) The GST Act permits only for issuance of show
cause notice based on the tax period. Therefore, if the
annual return is filed, the entire year would be considered
as a tax period and accordingly, the show cause notice
shall be issued based on the said annual returns.
(ii) If show cause notice is issued before the filing
of annual returns, the same can be issued based on the
filing of monthly returns;
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(iii) If show cause notice is issued after the filing
of annual returns or after the commencement of
limitation, the said notice shall be issued based on the
annual returns with regard to the relevant financial year.
(iv) No show cause notice can be clubbed and
issued for more than one financial year since the same is
impermissible in law.
(v) In these cases, without any jurisdiction, the
impugned show cause notices/orders came to be
issued/passed for more than one financial year, which is
impermissible in law and hence, the same is liable to be
quashed. Accordingly, the impugned show cause
notices/orders stand quashed based on the aspect of
clubbing of show cause notices for more than one
financial year.
29. In the result, these writ petitions are allowed to the extent as
stated above. No cost. Consequently, the connected miscellaneous
petitions are also closed.
21.07.2025
Speaking/Non-speaking order
Index : Yes / No
Neutral Citation : Yes / No
nsa
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W.P.No.29716 of 2024, etc., batch
To
1.The Senior Intelligence Officer
Directorate General Of Gst Intelligence,
Coimbatore Zonal Unit,
155-1, Lakshmanan Street,
Ukkadam, Coimbatore-641 001
2.The Superintendent of Central Tax CGST Central Excise
Coimbatore III D Range Buildings,
141 Srinivasa Nagar, SIDCO Industrial Estate,
Kuruchi, SIDCO Post Office, Coimbatore.
3.The Senior Intelligence Officer
Directorate General Of Gst Intelligence, Coimbatore Zonal Unit,
155-1, Lakshmanan Street,
Ukkadam, Coimbatore-641 001
4.The Assistant / Deputy Commissioner of Central Tax and
Central ExciseCoimbatore III Division, Elgi Building,
144, Trichy Road, Sungam Post Office, Coimbatore
5.The Additional Director
Directorate General Of Gst Intelligence,
Coimbatore Zonal Unit, 155-1,
Lakshmanan Street, Ukkadam,
Coimbatore-641 001
6.The Additional Joint Commissioner of Central Tax and
Central Excise
GST Commissionerate, 6/7 ATD Street,Racecourse, Coimbatore
7.The Superintendent,
Coimbatore Audit Circle 1,
Rakavis Towers, 1065,Trichy Road, Coimbatore
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W.P.No.29716 of 2024, etc., batch
-641045.
8.The Superintendent Of Gst And Central Excise,
Tirupur Ii Range, 1st Floor,
51, Elementary School Street,
Kumar Nagar, Tirupur-641603.
9.The Assistant Commissioner,
Office Of The Assistant Commissioner Of GstAnd Central
Excise, Tirupur Division,
2nd Floor, Elementary School Street,
Kumar Nagar, Tirupur-641603.
10.The Union of India Rep. by the Secretary,
Department of Revenue, Ministry of Finance,
No.137, North Block, New Delhi-1010 001.
11.The Good and Services Tax Council
GST Council Secretariat, rep. by its Chairman,
5th Floor Tower
II JeevanBharati Building
Janpath Road Connaught Palace
New Delhi 110001
12.The Central Board of Indirect Taxes and Customs
rep. by its director
CBIC North Block
New Delhi 110001
13.The Additional Commissioner
office of the principal commissioenr of CGST
and Central Excise,
Chennai North Commissionerate
Chennai 600 034
14.The Union of India
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W.P.No.29716 of 2024, etc., batch
Rep. by the Secretary,
Department of Revenue,
Ministry of Finance, No.137,
North Block, New Delhi-1010 001.
15.The Goods and Services Tax Council
5th floor Tower II
Jeevan Bharati Building
Janpath Road
Connaught Palace
New Delhi 110001
16.The Central Board of Indirect Taxes and Customs
CBIC North Block
New Delhi 110001
17.The Additional Commissioner
Chennai North Commissionerate
Chennai 600034
18.The State of Tamil Nadu
Fort St George Chennai 600009
19.The Deputy Commissioner (HPU)
Chennai South Commissionerate,
No. 692 Mhu Complex,
Nandanam, Chennai 600 035.
20.The Assistant Commissioner of GST and CE,
Valasaravakkam Division,
Chennai South Commissionerate,
Newry Towers, No.2054,
I Block, II Avenue, 12th Main Road,
Anna Nagar, Chennai .
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W.P.No.29716 of 2024, etc., batch
21.The Additional Commissioner Of Central Tax
Chennai North Commissionerate,
No.26/1,Mahatma Gandhi Road,
Chennai-600 034
22.The Deputy Commissioner
Audit Ii Commissionerate,
Mhu Complex, Anna Salai,
Nandanam, Chennai 600 035
23.The Assistant Commissioner GST AND CE.,
Villupuram Division, ( Maduranthakam Rage) Chennai
Outer Commissionerate, BSNL Campus,
Hospital Road, Villupuram 605 602
24.The Deputy Commissioner
Office of the Deputy Commissioner of CGST
and Central Excise,
Thyagaraya Nagar Division,
Chennai South Commissionerate
692, M.H.U. complex,
Anna Salai Nandanam, Chennai- 35.
25.The Additional Commissioner GST
Office of the commissioner of GST and Central Excise, GST
Bhawan
No 1 Foulkes Compound,
Anaimedu, salem 636 001
26.The Additional Commissioner
Office of the commissioner central Excise and GST, Newry
Towers,
No. 2054-I, II Avenue,
Anna Nagar, chennai- 40.
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27.The Assistant Commissioner
Ponneri Division Chennai Outer Commissionerate, Mogappair,
Chennai-600 037.
28.The Additional Commissioner of Central Tax
Chennai-outer, Newry Towers,
No. 2054-1, 2nd Avenue, Anna Nagar, Chennai 600040.
29.The Joint Commissioner of CGST and
Central Excise
Office Of The Commissioner Of Cgst And
Central Excise,
Chennai North Commissionerate,
No.26/1 Mahatma Gandhi Road,
Chennai 600034.
30.The Joint Commissioner Of Cgst And Central Excise
Office Of The Commissioner Of Cgst And Central Excise
Audit I Commissionerate,
No.1, 1775, Jawaharlal Nehru Inner Ring Road,
Anna Nagar West Extension, Chennai 600101.
31.The Commissioner Of Cgst And Central Excise
Office Of The Commissioner Of Cgst And Central Excise,
Chennai North Commissionerate
No.26/1, Mahatma Gandhi Road,
Chennai 600034.
32.The Joint Commissioner of CGST and Central Excise
Chennai North Commissionerate, Chennai
33.The Joint Commissioner Of Central Tax
Gst And Central Excise Appeal Ii Commissionerate
Newry Tower, 12th Main Road, Anna Nagar,
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W.P.No.29716 of 2024, etc., batch
Chennai-600 040.
34.The Assistant Commissioner of GST and Central Excise
Represented by its Proprietor
Mr. T.Sundarganesh
No.167, Gandhi road, Kanchipuram
Chengalpattu Road,
Ennaikaran, Kancheepuram
35.The Assistant Commissioner
Office Of The Assistant Commissioner Of Central Excise And Gst Anna
Nagar Division, Newry Towers, No.2054-i, Ii Avenue,
Anna Nagar, Chennai-600 040
36.The Deputy Commissioner
Circle VII, Audit I Commissionerate,
Office of Commissioner of GST and Central Excise
No,1775, Jawaharlal Nehru Inner Ring Road,
Anna Nagar West Extension
Chennai 600 101.
37.The Superintendent of Central tax
Range III Anna Nagar Division
No.2054, I Block, II Avenue,
12th Main Road, Anna. Nagar,
Chennai 600 040.
38.Superintendent of GST and Central Excise
Range II ALANDUR Division Office of the Superintendent Of CGST
AND Central Excise Alandur- II Range chennai South Commissionerate
First Floor ,
M.H.U. Complex, 692 Anna Salai,
Nandanam, Chennai -035.
39.Commercial Tax officer
Nanagnallur Assessment Circle,
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W.P.No.29716 of 2024, etc., batch
Chennai South III- Tamil Nadu.The Principal Commissioner Of Goods
And Service Tax And Central Excise,
Chennai North Commissionerate,
No.26/1, Mahatma Gandhi Road,
Chennai-600034.
40.The Senior Intelligence Officer
Directorate General of Goods and Service Tax Intelligence, Hyderabad
Zonal unit,
Block B, Kavuri Hills, Guttala Begumpet,
Madhapur, Hyderabad- 500 033.
41.The Additional Director
Directorate General of Goods and Service Tax Intelligence,
Hyderabad Zonal Unit, Block B, Kavuri Hills,
Guttala Begumpet, Madhapur,
Hyderabad-500033
42.The Joint Commissioner
Office of the Principal Commissioner of
CGST and Central Excise Chennai North
Commissionerate
No. 26/1, Mahatma Gandhi Road,
Chennai-600034
43.Additional Commissioner,
Office Of The Commissioner Of Goods And Service Tax And Central
Excise, Gst Bhawan, No.1, Foulkes Compound, Anaimedu,
Salem-636001.
44.The Assistant Commissioner of GST and Central Excise
Office of the Principal Commissioner of GST and Centra Excise,
No 6/7, ATD street,
Race course, Coimbatore 641 018
45.The Assistant/Deputy Commissioner of
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GST and Central Excise
Coimbatore III Division
Aadithya Towers, Trichy Road, Ramanathapuram, Coimbatore 641 045
46.Additional Commissioner, Salem
Office Of The Commissioner Of Goods
And Service Tax And Central Excise,
Gst Bhawan, No.1, Foulkes Compound,
Anaimedu, Salem-636 001
47.The Joint Commissioner of Central Tax
Commissioner of GST and Central Excise
Newry Tower . No.2054- I. II Avenue,
anna nagar, Chennai -40.
48.The Deputy Commissioner
Purasaiwakam Division,
Chennai North Commissioerate,
No. 2054 I Block Ii Avenue,
12th Main Road, Anna Nagar,
Chennai 040.
49.Additional Commissioner salem
Office of the Commissioner of Goods and
Service Tax and Central Excise,
GSt Bhawan No 1, Foulkes Compound,
Anaimedu, Salem 636 001
50.The Superintendent of GST and Central
Excise
Office of the Superintednet of GST and
Cenral Exise, Range 1 B, Puducherry,
No 48/1, Second Floor Azeez Nagar,
Reddiyarpalayam Puducherry 605 010
51.Additional Commissioner Appeals I
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W.P.No.29716 of 2024, etc., batch
Office of the Commissioner of GST
andCentral Excise (Appeals-I)
26 1, Mahatma Gandhi Road,
Nungambakkam, Chennai – 600034
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W.P.No.29716 of 2024, etc., batch
KRISHNAN RAMASAMY.J.,
nsa
W.P.Nos.29716 of 2024, etc., batch
21.07.2025
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