Madras High Court
WP(MD)/28738/2026 of Tvl Saravanan Vs The Deputy State Tax Officer on 14 October 2026
WP(MD) Nos. 28738 & 28739 of 2026
BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT
DATED: 14-10-2026
CORAM
THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY
WP(MD) Nos. 28738 & 28739 of 2026
CNR:{HCMD011416782026}
and
WMP(MD) Nos.21810 & 21835 of 2026
WP(MD) No. 28738 of 2026
Tvl.Saravanan,
No.9/13, Ammanpatti,
Perumalthevanpatti, Thiruchuli,
Virudhunagar - 623 603.
..Petitioner(s)
Vs
The Deputy State Tax Officer - 1/
The Deputy Commercial Tax Officer,
..Respondent(s)
PRAYER: Writ Petition, filed under Article 226 of the Constitution of India, praying this Court for issuance of a Writ of Certiorarified Mandamus to call for the impugned assessment order on the file of respondent vide GSTIN: 33EQDPS1350E1Z5/2019-20 dated 20.01.2025 and in Rectification Order Reference No: ZD330125156526J dated 21.01.2025 and quash the same as illegal and devoid of merits and direct the respondent to redo the assessment proceedings for the year 2019-20.
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WP(MD) Nos. 28738 & 28739 of 2026
For Petitioner :
Mr.Raja.Karthikeyan
For Respondent :
Mr.R.Parthiban
Special Government Pleader
WP(MD) No. 28739 of 2026
Tvl.Saravanan,
No.9/13, Ammanpatti,
Perumalthevanpatti, Thiruchuli,
Virudhunagar - 623 603.
..Petitioner(s)
Vs
The Assistant Commissioner (ST),
..Respondent(s)
PRAYER: Writ Petition filed under Article 226 of the Constitution of India, praying this Court for issuance of a Writ of Certiorarified Mandamus to call for the impugned assessment order on the file of respondent vide GSTIN. 33EQDPS1350E1Z5/2021-22 and in summary order Reference No ZD331125182408G dated 11.11.2025 and quash the same as illegal and devoid of merits and direct the respondent to redo the assessment proceedings for the year 2021-22.
For Petitioner :
Mr.Raja.Karthikeyan
For Respondent :
Mr.R.Parthiban
Special Government Pleader
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WP(MD) Nos. 28738 & 28739 of 2026
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COMMON ORDER
Orders dated 20.01.2025 and 11.11.2025 in relation to assessment periods 2019-20 and 2021-22, respectively, are assailed in these Writ Petitions primarily on the ground of duplication.
2. Adverting to earlier orders dated 06.12.2022 and 30.11.2022 for the corresponding assessment periods, learned counsel for the petitioner submits that the same issues pertaining to the same assessment period were dealt with therein. He adds that appeals were lodged before the appellate authority challenging said orders and that the appeals are pending.
3. Mr.R.Parthiban, learned Special Government Pleader for the respondent, submits that order dated 20.01.2025 deals with two issues and that the second issue pertaining to the reconciliation of turnover in GSTR-7 with the supplies declared in GSTR-3B was dropped. He submits that the first issue relates to the reconciliation of GSTR-1 with GSTR-9.
4. In response, learned counsel for the petitioner points out that the turnover declared in the petitioner's GSTR-1 statement is the same as that reflected in the GSTR-7. Therefore, he submits that there is complete __________
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WP(MD) Nos. 28738 & 28739 of 2026 overlap between the 2 orders. He has handed over a copy of the GSTR-1 statement for 2019-20.
5. On examining the GSTR-1 statement of the petitioner for 2019-20, the submission that the turnover reflected therein tallies with that mentioned in the GSTR-7 returns filed by the deductors is liable to be accepted. As a consequence, the contention with regard to duplication is liable to be accepted. In view thereof, both the orders impugned herein are set aside and these matters are remanded to the assessing officer for reconsideration. After taking note of earlier orders dated 06.12.2022 and 30.11.2022 and the appeals in relation thereto, fresh orders shall be issued within 5 months from the date of receipt of a copy of this order.
6. These Writ Petitions are disposed of on the above terms. There shall be no order as to costs. Consequently, connected Miscellaneous Petitions are closed. 14-10-2026 Index: No Speaking Neutral Citation: No JEN __________
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WP(MD) Nos. 28738 & 28739 of 2026 To
1. The Deputy State Tax Officer - 1/ The Deputy Commercial Tax Officer,
2. The Assistant Commissioner (ST),
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WP(MD) Nos. 28738 & 28739 of 2026 SENTHILKUMAR RAMAMOORTHY, J. JEN WP(MD) Nos. 28738 & 28739 of 2026 14-10-2026 __________
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