WP No. 23174 of 2026 __________ Page1 of 4 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 10-07-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 23174 of 2026 and W.M.P.No.25119 of 2026 M/S. Lakshmi Security Services and Manpower Consultancy, Represented by its Authorised Signatory -Dhienagaran Swaminathan, 46,Govindasamy Nagar, Sellankuppam, Cuddalore, Tamil Nadu 607003. ..Petitioner(s) Vs The Assistant Commissioner (ST) Office of the Assistant Commissioner, Cuddalore Town Assessment Circle, Cuddalore. ..Respondent(s) PRAYER: Writ Petition filed under Article 226 of The Constitution of India praying for the issuance of a Writ of Certiorari, calling for the records relating to the impugned proceedings passed by the Respondent the Impugned Order in GSTIN 33AJAP5260A1Z4/2021-22 dated 30.12.2025 along with the Consequential summary of Order U/s 73 in FORM GST DRC 07 bearing with Ref ZD33122545255M dated 30.12.2025 for the Period 2021-22 to quash the same. For Petitioner(s): Ms.R. Hemalatha https://www.mhc.tn.gov.in/judis WP No. 23174 of 2026 __________ Page2 of 4 For Respondent(s): Ms. Amirta Poonkodi Dinakaran, Government Counsel (Tax) ************ ORDER The petitioner provides security services and manpower consultancy. In relation thereto, pursuant to show cause notice dated 29.09.2025, impugned order dated 30.12.2025 was issued. 2. Learned counsel for the petitioner submits that manpower supply is made on RCM basis. As regards security services provided by the petitioner to educational institutions, it is contended that this falls within serial no.66 of Notification No.12/2017 Central Tax (Rate) dated 28.06.2017 and is, consequently, exempt from taxes. 3. Ms.Amirta Poonkodi Dinakaran, learned Government Counsel (Tax), submits that the impugned order was issued because the petitioner did not provide documentary evidence to establish that such services were provided to an educational institution engaged in pre-school to higher secondary education or its equivalent. https://www.mhc.tn.gov.in/judis WP No. 23174 of 2026 __________ Page3 of 4 4. From the documents on record, it appears prima facie that the services provided by the petitioner fall within entry 66. This, however, is required to be substantiated with documents. Towards that end, the impugned order is set aside and the matter is remanded for re-consideration. After providing a reasonable opportunity to the petitioner, including a personal hearing, a fresh order shall be issued within three months from the date of receipt of a copy of this order. 5. This writ petition is disposed of on the above terms. There shall be no order as to costs. Consequently, the connected writ miscellaneous petition is closed. 10-07-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To The Assistant Commissioner (ST) Office of the Assistant Commissioner, Cuddalore Town Assessment Circle, Cuddalore. https://www.mhc.tn.gov.in/judis WP No. 23174 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 23174 of 2026 and W.M.P.No.25119 of 2026 10-07-2026 https://www.mhc.tn.gov.in/judis