Madras High Court
WP/41121/2026 of M/s.SJR Pharmaceuticals Vs The State Tax Officer on 12 October 2026
WP No. 41121 of 2026
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IN THE HIGH COURT OF JUDICATURE AT MADRAS
DATED: 13-10-2026
CORAM
THE HON'BLE MR JUSTICE KRISHNAN RAMASAMY
WP No. 41121 of 2026
and WMP.Nos.46152 and 46168/2026
CNR:{HCMA012161752026}
M/s.SJR Pharmaceuticals
Represented by its Partner Jayashankar S
No. 8/24, Norton Road,
Mandaveli,Chennai,
Tamil Nadu 600 028
..Petitioner(s)
Vs
1. The State Tax Officer
Mandaveli Assessment Circle,
No. 242, Integrated Commercial taxes and registration department, Nandanam,Chennai 600 035.
2. The Deputy State Tax Officer
Mandaveli Assessment Circle,No.419,
Integrated Commercial taxes Building,
Nandanam,
Chennai 600 035.
..Respondent(s)
PRAYER: The Writ Petition is filed under Article 226 of the Constitution of India seeking the issuance of a Writ of Certiorarified Mandamus calling for the entire records pertaining to a) The impugned Assessment Order dated 10.08.2024, culminating in FORM GST DRC-07 dated 13.08.2024 vide Ref No.
ZD330824109260S, issued under Section 73 of the CGST/TNGST Act, 2017, issued by the 1st Respondent, and b) The impugned Assessment Order dated 13.08.2024 vide Ref No. ZD330824096540A passed under Section 73 of the CGST/TNGST Act, 2017, issued by the 2nd Respondent, and c) The impugned Assessment Order dated 19.08.2024 vide Ref No. ZD330824146107H passed
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WP No. 41121 of 2026
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under Section 73 of the CGST/TNGST Act, 2017, issued by the 2nd Respondent, and d) The consequential Bank Attachment Notice in FORM GST
DRC-13 dated 12.08.2026 issued under Section 79 of the CGST/TNGST Act, 2017, issued by the 1st Respondent, all issued by the Respondents in respect of GSTIN 33ACSFS4785L1Z8, quash the same as being illegal, arbitrary, without jurisdiction and violative of the principles of natural justice, and consequently direct the 1st Respondent to lift the attachment over the Petitioners bank account forthwith and, if so advised, undertake any fresh adjudication strictly in accordance with the provisions of the CGST Act, 2017, the Tamil Nadu GST
Act, 2017 and the Rules made thereunder, after issuing a proper Show Cause Notice, furnishing all relied upon materials and affording the Petitioner an effective and meaningful opportunity of personal hearing.
For Petitioner(s):
Mr.D.Parasuram for Mr.Sankar Ganesh S
For Respondent(s):
Mr.I.Dinesh, Additional Government Pleader (Taxes)
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Order
This writ petition has been filed challenging the impugned orders dated 10.08.2024, 13.08.2024 and 19.08.2024 passed by the respondent.
2. Mr.I.Dinesh, learned Additional Government Pleader (Taxes), takes notice on behalf of the respondent. By consent of the parties, the main writ petition is taken up for disposal at the admission stage itself.
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3. The learned counsel appearing for the petitioner submitted that the respondent initiated proceedings by issuing Form GST DRC-01A, alleging the non-filing of the Annual Return for the financial year 2019-20. The respondent issued multiple proceedings arising out of overlapping notices relating to the very same assessment year and proceeded to pass three impugned ex-parte adjudication orders without granting the petitioner an effective and meaningful opportunity for a personal hearing. Further, he submitted that the petitioner undertakes to pay 100% of the disputed tax amount to the respondent, and has also made an endorsement to that effect in the case bundle. Hence, he requested this Court to set aside the impugned orders and grant an opportunity to the petitioner to present their case before the respondent.
4. On the other hand, the learned Additional Government Pleader (Taxes) appearing for the respondent fairly admitted that the respondent had initiated proceedings pertaining to multiple show cause notices, resulting in multiple tax demands, and had passed three impugned assessment orders without providing an effective opportunity for a personal hearing. Therefore, he requested this Court to remit the matter back to the respondent, subject to the payment of 100% of the disputed tax amount by the petitioner.
5. Heard the learned counsel on both sides and perused the materials available on record.
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6. Upon a perusal of the records, this Court is of the view that the proceedings pertaining to multiple show cause notices, multiple tax demands, and overlapping adjudications for the same assessment year were conducted simultaneously. This resulted in considerable procedural confusion and prejudiced the petitioner’s right to effectively defend the proceedings. In such circumstances, this Court is of the view that the impugned assessment orders, which confirmed the proposals contained in the show cause notices, were passed without affording any opportunity of a personal hearing to the petitioner. 7.. Further, it was submitted by the learned counsel for the petitioner that the petitioner is willing to pay 100% of the disputed tax amount to the respondent. In such view of the matter, this Court is inclined to set aside the impugned orders dated 10.08.2024, 13.08.2024 and 19.08.2024 passed by the respondent. Accordingly, this Court passes the following order:-
(i) The impugned orders dated 10.08.2024, 13.08.2024 and 19.08.2024 are set aside and the matter is remanded to the respondent for fresh consideration on condition that the petitioner shall pay 100% of disputed tax amount to the respondent within a period of four weeks from the date of receipt of a copy of this order. The setting aside of the impugned order will take effect from the date of payment of the said amount.
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(ii) The petitioner shall file their reply/objection along with the required documents, if any, within a period of three weeks from the date of payment of amount as stated above.
(iii) On filing of such reply/objection by the petitioner, the respondent shall consider the same and issue a 14 days clear notice, by fixing the date of personal hearing, to the petitioner and thereafter, pass appropriate orders on merits and in accordance with law, after hearing the petitioner, as expeditiously as possible.
iv) Considering the fact that the impugned order itself have been set aside, this Court is of the opinion that the attachment made on the bank account of the petitioner cannot survive any longer and hence, it is to be lifted. As a sequel, the concerned Bank is directed to de-freeze the bank account of the petitioner, immediately upon the production of a copy of this order.
11. With the above directions, this writ petition is disposed of. No costs. Consequently, WMP.No.46152/2026 is ordered and WMP.NO.46168/2026 is closed. 13-10-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No SK
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To
1. The State Tax Officer Mandaveli Assessment Circle, No. 242, Integrated Commercial taxes and registration department, Nandanam,Chennai 600 035.
2. The Deputy State Tax Officer Mandaveli Assessment Circle,No.419, Integrated Commercial taxes Building, Nandanam, Chennai 600 035.
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WP No. 41121 of 2026 __________
KRISHNAN RAMASAMY J. SK WP No. 41121 of 2026 13-10-2026
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WP No. 41121 of 2026 __________
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