Madras High Court
WP/41183/2026 of Ms SJR Pharamaceuticals Vs The Deputy State Tax Officer on 12 October 2026
WP No. 41183 of 2026
IN THE HIGH COURT OF JUDICATURE AT MADRAS
DATED: 12-10-2026
CORAM
THE HON'BLE MR JUSTICE KRISHNAN RAMASAMY
WP No. 41183 of 2026
CNR:{HCMA012171202026}
AND
WMP NO. 46233 OF 2026,WMP NO. 46222 OF 2026
Ms SJR Pharamaceuticals,
Represented by its Partner Mr Jayashankar S
No. 8/24, Norton Road,
Mandaveli, Chennai,
Tamil Nadu 600 028
..Petitioner(s)
Vs
1. The Deputy State Tax Officer
Mandaveli Assessment Circle,
No.419, Integrated Commercial Taxes Building, Nandanam, Chennai-600 035
2. The State Tax Officer
Mandaveli Assessment Circle,
No. 423, Integrated Commercial Taxes and registration department Building, Nandanam, Chennai 600 035.
..Respondent(s)
Prayer: This writ petition is filed under Article 226 of the Constitution of India, praying to issue a Writ of Certiorarified Mandamus calling for the records pertaining to a) the impugned Assessment Order dated 03.07.2024, culminating in FORM GST DRC-07 dated 04.07.2024 vide Ref No. ZD3307240497447
issued under Section 73 of the CGST/TNGST Act, 2017 issued by the 1st Respondent b) the impugned Assessment Order dated 11.11.2024 vide Ref No.
ZD331124068555G passed under Section 73 of the CGST/TNGST Act, 2017
issued by the 1st respondent c) the impugned Assessment Order dated 19.02.2025 vide Ref No. ZD330225193131T passed under Section 73 of the
WP No. 41183 of 2026
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 passed under Section 79 of the CGST/TNGST Act, 2017, issued by the Respondents all issued by the Respondent 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 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.Parasuram for Mr.Sankar Ganesh S
For Respondent(s):
Mr.B.Sivaraman, Government Advocate (Taxes)
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Order
These Writ Petitions have been filed challenging the impugned assessment orders dated 03.07.2024, 11.11.2024, and 19.02.2025, as well as the consequential bank attachment notice dated 12.08.2026 issued by the respondents.
2. The learned counsel appearing for the petitioner submitted that the petitioner is engaged in the pharmaceutical business and has been regularly filing its returns. The respondents initiated proceedings under Section 73 of the CGST/TNGST Acts by issuing notices through the GST common portal, which
WP No. 41183 of 2026
were not effectively communicated to the petitioner. Under such circumstances, the respondents passed the first impugned assessment order dated 03.07.2024. Subsequently, separate independent proceedings were initiated alleging a mismatch between the GSTR-1 and GSTR-3B returns, following which the respondents proceeded to pass the second impugned assessment order dated 11.11.2024. Thereafter, the respondents initiated yet another adjudication for the very same assessment year and ultimately passed the third impugned assessment order dated 19.02.2025.
3. It is submitted by the learned counsel for the petitioner that repeated adjudication proceedings relating to substantially identical issues were simultaneously pursued against the petitioner. He contended that such repeated assessments amount to an impermissible duplication of proceedings. Further, being aggrieved by the assessment order dated 19.02.2025, the petitioner preferred a statutory appeal before the competent Appellate Authority, which is currently pending adjudication. Aggrieved by this duplication of proceedings, the petitioner has preferred the present writ petition.
4. The learned Government Advocate (Taxes), who accepts notice on behalf of the respondents, fairly submitted that the impugned assessment orders dated 03.07.2024 and 11.11.2024 are a duplication of the issues already covered in the order dated 19.02.2025. Hence, he submitted that the said two orders may be set aside.
WP No. 41183 of 2026
5. Heard both sides and perused the materials available on record.
6. In view of the fair submission made by the learned Government Advocate for the respondents, the impugned assessment orders dated 03.07.2024 and 11.11.2024 stand set aside. Since the petitioner has already preferred a statutory appeal against the third impugned assessment order dated 19.02.2025, this Court is not inclined to interfere with the same, and it is open to the petitioner to contest the matter before the Appellate Authority in accordance with law.
7. With the above observations, these Writ Petitions stand disposed of. No costs. Consequently, W.M.P. No. 46222 of 2026 is allowed, and W.M.P. No. 46233 of 2026 stands closed. 12-10-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No SK To
1. The Deputy State Tax Officer Mandaveli Assessment Circle, No.419, Integrated Commercial Taxes Building, Nandanam, Chennai-600 035
2. The State Tax Officer Mandaveli Assessment Circle, No. 423, Integrated Commercial Taxes and registration department Building, Nandanam, Chennai 600 035.
WP No. 41183 of 2026
KRISHNAN RAMASAMY J. SK WP No. 41183 of 2026 AND WMP NO. 46233 OF 2026,WMP NO. 46222 OF 2026 12-10-2026