WP Nos. 24637 & 24655 of 2026 __________ Page1 of 4 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 30-06-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP Nos. 24637 & 24655 of 2026 and WMP.Nos.26875, 26876, 26889 & 26892 of 2026 Jagadeesan Suseela No. 56, eswaran Kovil Street, Nandivaram, Guduvancheri, Chengalpattu Tamilnadu-603 202. ..Petitioner Vs State Tax Officer No.42-Wahab Nagar Thirukazhukundram-603 109. ..Respondent Prayer : Writ Petition is filed under Article 226 of the Constitution of India praying for issuance of Writ of Certiorari calling for the records of the Impugned Order issued by the Respondent in GSTIN 33EUUPS1270Q1ZO/2022-23 dated 05.03.2026 along with Summary of Order in FORM DRC 07 bearing Reference No. ZD330326041921N and quash the same. For Petitioner: Mr. V.Prashanth Kiran For Respondent: Mr. R. Sethu Prabakaran Government Counsel (Tax) https://www.mhc.tn.gov.in/judis WP Nos. 24637 & 24655 of 2026 __________ Page2 of 4 COMMON ORDER In both these writ petitions, orders of assessment imposing GST on seigniorage are challenged. In similar matters, subject to payment of 10% of the tax demand, the impugned orders were set aside. 2. Mr. R.Sethu Prabakaran, learned Government Counsel (Tax), accepts notice on behalf of the respondent. 3. Learned counsel for the petitioner submits that amounts in excess of 10% of the tax demand under the two impugned orders were recovered from the petitioner’s electronic cash ledger and electronic credit ledger. He has handed over documents in that regard. He adds that a substantial amount was recovered from the bank account of the petitioner’s purchaser. 4. Subject to verifying and confirming that more than 10% of the disputed tax demand under the impugned orders were recovered from the petitioner’s electronic cash and credit ledgers, the impugned orders are set aside and these matters are remanded for re-consideration. After providing a reasonable opportunity to the petitioner, fresh orders shall be issued within three months from the date of receipt of a copy of this order. The implementation of such order shall be kept in abeyance pending decision of the Supreme Court in the https://www.mhc.tn.gov.in/judis WP Nos. 24637 & 24655 of 2026 __________ Page3 of 4 Special Leave Petitions pertaining to imposition of GST on seigniorage. In view of the assessment orders being set aside, all orders of attachment, including against the petitioner’s garnishee, shall stand raised. 5. The writ petitions are disposed of on the above terms. Consequently, connected miscellaneous petitions are closed. There shall be no order as to costs. 30-06-2026 Index : Yes/No Neutral Citation : Yes/No KJ To State Tax Officer No.42-Wahab Nagar Thirukazhukundram-603 109. https://www.mhc.tn.gov.in/judis WP Nos. 24637 & 24655 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. KJ WP Nos. 24637 & 24655 of 2026 and WMP.Nos.26875, 26876, 26889 & 26892 of 2026 30-06-2026 https://www.mhc.tn.gov.in/judis