WP No. 47019 of 2025 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 08-12-2025 CORAM THE HONOURABLE MR JUSTICE C. SARAVANAN WP No. 47019 of 2025 AND WMP NO. 52594 OF 2025,WP NO. 47063 OF 2025,WMP NO. 52534 OF 2025,WMP NO. 52591 OF 2025,WMP NO. 52539 OF 2025,WP NO. 47065 OF 2025,WMP NO. 52533 OF 2025,WMP NO. 52540 OF 2025,WMP NO. 52599 OF 2025,WMP NO. 52600 OF 2025,WP NO. 47025 OF 2025 WP No. 47021 of 2025 AND WMP NO. 52536 OF 2025,WMP NO. 52537 OF 2025 1. M/s. Sydney Apparels Rep. by its Partner R. Velmurugan SF.No. 572, NA,Kuttai Thottam Sirupuluvapatti, Post,Tiruppur 641 603 Petitioner(s) Vs 1. The Assistant Commissioner ST Central II Assessment circle, Tiruppur district, Tiruppur Respondent(s) WMP No. 52594 of 2025 1. M/s. Sydney Apparels Rep. by its Partner R. Velmurugan SF.No. 572, NA,Kuttai Thottam Sirupuluvapatti, Post,Tiruppur 641 603 Petitioner(s) Vs 1. The Assistant Commissioner ST Central II Assessment Circle, Tiruppur Distrct, Tiruppur Respondent(s) WP No. 47063 of 2025 1. M/s. Sydney Apparels https://www.mhc.tn.gov.in/judis WP No. 47019 of 2025 Rep. by its Partner R. Velmurugan SF.No. 572, NA,Kuttai Thottam Sirupuluvapatti, Post,Tiruppur 641 603 Petitioner(s) Vs 1. The Assistant Commissioner ST Central II Assessment Circle, Tiruppur Distrct, Tiruppur Respondent(s) WMP No. 52534 of 2025 1. M/s. Sydney Apparels Rep. by its Partner R. Velmurugan SF.No. 572, NA,Kuttai Thottam Sirupuluvapatti, Post,Tiruppur 641 603 Petitioner(s) Vs 1. The Assistant Commissioner ST Respondent(s) WMP No. 52591 of 2025 1. M/s. Sydney Apparels Rep. by its Partner R. Velmurugan SF.No. 572, NA,Kuttai Thottam Sirupuluvapatti, Post,Tiruppur 641 603 Petitioner(s) Vs 1. The Assistant Commissioner ST Central II Assessment Circle, Tiruppur Distrct, Tiruppur Respondent(s) WMP No. 52539 of 2025 1. M/s. Sydney Apparels Rep. by its Partner R. Velmurugan SF.No. 572, NA,Kuttai Thottam Sirupuluvapatti, Post,Tiruppur 641 603 Petitioner(s) https://www.mhc.tn.gov.in/judis WP No. 47019 of 2025 Vs 1. The Assistant Commissioner Respondent(s) WP No. 47065 of 2025 1. M/s. Sydney Apparels Rep. by its Partner R. Velmurugan SF.No. 572, NA,Kuttai Thottam Sirupuluvapatti, Post,Tiruppur 641 603 Petitioner(s) Vs 1. The Assistant Commissioner ST Respondent(s) WMP No. 52533 of 2025 1. M/s. Sydney Apparels Rep. by its Partner R. Velmurugan SF.No. 572, NA,Kuttai Thottam Sirupuluvapatti, Post,Tiruppur 641 603 Petitioner(s) Vs 1. The Assistant Commissioner ST Respondent(s) WMP No. 52540 of 2025 1. M/s. Sydney Apparels Rep. by its Partner R. Velmurugan SF.No. 572, NA,Kuttai Thottam Sirupuluvapatti, Post,Tiruppur 641 603 Petitioner(s) Vs 1. The Assistant Commissioner Respondent(s) WMP No. 52599 of 2025 https://www.mhc.tn.gov.in/judis WP No. 47019 of 2025 1. M/s. Sydney Apparels Rep. by its Partner R. Velmurugan SF.No. 572, NA,Kuttai Thottam Sirupuluvapatti, Post,Tiruppur 641 603 Petitioner(s) Vs 1. The Assistant Commissioner ST Respondent(s) WMP No. 52600 of 2025 1. M/s. Sydney Apparels Rep. by its Partner R. Velmurugan SF.No. 572, NA,Kuttai Thottam Sirupuluvapatti, Post,Tiruppur 641 603 Petitioner(s) Vs 1. The Assistant Commissioner ST Respondent(s) WP No. 47025 of 2025 1. M/s. Sydney Apparels Rep. by its Partner R. Velmurugan SF.No. 572, NA,Kuttai Thottam Sirupuluvapatti, Post,Tiruppur 641 603 Petitioner(s) Vs 1. The Assistant Commissioner Respondent(s) 1. M/s. Sydney Apparels Rep. by its Partner R. Velmurugan SF.No. 572, NA,Kuttai Thottam Sirupuluvapatti, Post,Tiruppur 641 603 Petitioner(s) Vs https://www.mhc.tn.gov.in/judis WP No. 47019 of 2025 1. The State Tax officer Central II Assessment circle, Tiruppur district, Tiruppur Respondent(s) WMP No. 52536 of 2025 1. M/s. Sydney Apparels Rep. by its Partner R. Velmurugan SF.No. 572, NA,Kuttai Thottam Sirupuluvapatti, Post,Tiruppur 641 603 Petitioner(s) Vs 1. The State Tax officer Respondent(s) WMP No. 52537 of 2025 1. M/s. Sydney Apparels Rep. by its Partner R. Velmurugan SF.No. 572, NA,Kuttai Thottam Sirupuluvapatti, Post,Tiruppur 641 603 Petitioner(s) Vs 1. The State Tax officer Respondent(s) WP No. 47019 of 2025 PRAYER calling for the orders of the respondent in Form DRC-07 with reference no. ZD330824301198H dated 31.08.2024 passed under Section 73 of the TNGST Act, 2017 pertaining to the financial year 2019-20 and quash the same as illegal, devoid of merits and in violation of principles of natural justice and pass WMP No. 52594 of 2025 PRAYER to stay all further proceedings pursuant to the impugned in Form DRC-07 with reference no. ZD3302251121229 dated 12.02.2025 passed by the respondnet pending disposal of the writ petition https://www.mhc.tn.gov.in/judis WP No. 47019 of 2025 WP No. 47063 of 2025 PRAYER calling for the orders of the respondent in Form DRC-07 with reference no. ZD3302251121229 dated 12.02.2025 passed under Section 73 of the TNGST Act, 2017 pertaining to the financial year 2020-21 and quash the same as illegal, devoid of merits and in violation of principles of natural justice and pass such further or other orders as this Honble Court may deem fit and proper in the above facts and circumstances of the case and thus render justice and for other relieves. WMP No. 52534 of 2025 PRAYER to stay all further proceedings pursuant to the impugned order in Form DRC-07 with reference no. ZD330824301198H dated 31.08.2024 passed by the respondent pending disposal of the writ petition WMP No. 52591 of 2025 PRAYER To dispense with the production of the certified copy of the impugned order in Form Form DRC-07 with reference no. ZD3302251121229 dated 12.02.2025 issued by the respondnet for time being WMP No. 52539 of 2025 PRAYER to dispense with the production of the certified copy of the impugned order in Form DRC-07 with reference no.ZD330824282440G dated 29.08.2024 issued by the respondent for time being WP No. 47065 of 2025 PRAYER calling for the orders of the respondent in Form DRC-07 with reference no. ZD330225223646L dated 21.02.2025 passed under Section 73 of the TNGST Act, 2017 pertaining to the financial year 2020-21 and quash the same as illegal, devoid of merits and in violation of principles of natural justice and pass such further or other orders as this Honble Court may deem fit and proper in the above facts and circumstances of the case and thus render justice and for other relieves. WMP No. 52533 of 2025 PRAYER to dispense with the production of the certified copy of the impugned order in Form DRC-07 with reference no. ZD330824301198H dated 31.08.2024 issued by the respondent for time being WMP No. 52540 of 2025 https://www.mhc.tn.gov.in/judis WP No. 47019 of 2025 PRAYER to stay all further proceedings pursuant to the impugned order in Form DRC-07 with reference no. ZD330824282440G dated 29.08.2024 passed by the respondent pending disposal of the writ petition WMP No. 52599 of 2025 PRAYER To dispense with the production of the certified copy of the impugned order in Form DRC-07 with reference no. ZD330225223646L dated 21.02.2025 issued by the respondent, for time being WMP No. 52600 of 2025 PRAYER To stay all further proceedings pursuant to the impugned order in Form DRC-07 with reference no. ZD330225223646L dated 21.02.2025 passed by the respondent, pending disposal of the writ petition WP No. 47025 of 2025 PRAYER calling for the orders of the respondent in Form DRC-07 with reference no. ZD330824282440G dated 29.08.2024 passed under Section 73 of the TNGST Act, 2017 pertaining to the financial year 2019-20 and quash the same as illegal, devoid of merits and in violation of principles of natural justice and pass orders WP No. 47021 of 2025 PRAYER calling for the orders of the respondent in Form DRC-07 with reference no. ZD330824204982C dated 21.08.2024 passed under Section 73 of the TNGST Act, 2017 pertaining to the financial year 2019-20 and quash the same as illegal, devoid of merits and in violation of principles of natural justice and pass In All W.P’s For Petitioner(s): M. Varun Pandian G.Ajay Raj U.Shanmathi For Respondent: Mr.T. N.C. Kaushik COMMON ORDER MrT. N.C. Kaushik, learned Government Advocate takes notice for the Respondent. https://www.mhc.tn.gov.in/judis WP No. 47019 of 2025 2.All the above writ petitions are disposed of at the stage of admission itself with the consent of the learned counsel for the Petitioner and the learned Additional Government Pleader for the Respondents. 3. In these writ petitions, the petitioners have challenged the respective orders as detailed below: S.No. Writ Petition Assessment order Challenged Tax Period Total Tax Issues 1 WP No. 47019/2025 Order dated 31.08.2024 2019-20 Rs.65,16,679/- Excess claim of ITC and Non- generation of 3-way for inward and outward supplies 2 Wp.No.47021/2025 Order dated 21.08.2024 2019-20 Rs.3,58,949/- Difference between GSTR-2A and GSTReB 3 Wp No. 47025/2025 Order dated 29.08.2024 2019-20 Rs.15,81,951/- Under Declaration of Tax Liability in Annual Returns in GSTR-09 4 WP No. 47063/2025 Order dated 12.02.2025 2020-21 Rs.3,77,752/- Under declaration of Tax liability in annual rturns in Form GSTR-09 5 WP.No.47065/2025 Order dated 21.02.2025 2020-21 Rs.10,13,389/- Under declaration of Tax liability in annual returns in Form GSTR-09 4. The learned counsel for the petitioner submits that the petitioner is willing to deposit the amounts as a condition for de novo proceedings, as the learned counsel for the petitioner failed to reply to the respective Show Cause Notices that preceded the impugned orders. 5. Recording the above submission and following the consistent view taken under similar circumstances, the impugned orders are quashed and the cases are remitted back to the concerned respondents subject to the petitioner https://www.mhc.tn.gov.in/judis WP No. 47019 of 2025 depositing the following amounts within a period of thirty (30) days from the date of receipt of a copy of this order. S.No Writ Petition Assessment order Challenged Tax Period Total Tax Amount to be paid 1 WP No. 47019/2025 Order dated 31.08.2024 2019-20 Rs.65,16,679/- 50% of the disputed tax 2 Wp.No.470 21/2025 Order dated 21.08.2024 2019-20 Rs.3,58,949/- 50% of the disputed tax 3 Wp No. 47025/2025 Order dated 29.08.2024 2019-20 Rs.15,81,951/- 50% of the disputed tax 4 WP No. 47063/2025 Order dated 12.02.2025 2020-21 Rs.3,77,752/- 25% of the disputed tax 5 WP.No.4706 5/2025 Order dated 21.02.2025 2020-21 Rs.10,13,389/- 25% of the disputed tax 6. The Petitioner shall also file a reply to the Show Cause Notice in DRC-01 issued for the respective tax periods together with requisite documents to substantiate the case by treating the respective impugned assessment Order as an addendum to the Show Cause Notices in Drc-01 dated 31.05.2024. 7. In case the petitioner complies with the above stipulated conditions, the respondent shall proceed to pass fresh orders on merits and in accordance with law as expeditiously as possible, preferably, within a period of three (3) months thereafter, after hearing the Petitioner. Subject to petitioner depositing the aforesaid amount as ordered above, bank attachment if any shall stand raised/vacated. https://www.mhc.tn.gov.in/judis WP No. 47019 of 2025 8. In case the petitioner fails to comply with any of the conditions stipulated above, the respondent is at liberty to proceed against the petitioner in accordance with law as if these Writ Petitions were dismissed in limine today. 9. With these directions, these Writ Petitions stand disposed of. Consequently, connected miscellaneous petitions are closed. No costs. 08.12.2025 Index:Yes/No Speaking/Non-speaking order Internet:Yes Neutral Citation:Yes/No smn https://www.mhc.tn.gov.in/judis WP No. 47019 of 2025 To 1.The Assistant Commissioner ST Central II Assessment circle, Tiruppur district, Tiruppur To 1.The Assistant Commissioner ST https://www.mhc.tn.gov.in/judis WP No. 47019 of 2025 C.SARAVANAN J. smn WP No. 47019 of 2025 AND WMP NO. 52594 OF 2025,WP NO. 47063 OF 2025,WMP NO. 52534 OF 2025,WMP NO. 52591 OF 2025,WMP NO. 52539 OF 2025,WP NO. 47065 OF 2025,WMP NO. 52533 OF 2025,WMP NO. 52540 OF 2025,WMP NO. 52599 OF 2025,WMP NO. 52600 OF 2025,WP NO. 47025 OF 2025 WP No. 47021 of 2025 AND WMP NO. 52536 OF 2025,WMP NO. 52537 OF 2025 08-12-2025 https://www.mhc.tn.gov.in/judis