Madras High Court

WP(MD)/28730/2026 of TVL. S.G. FAB Vs The Assistant Commissioner ( on 6 October 2026

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W.P.(MD) No.28730 of 2026

BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT

DATED : 06.10.2026

CORAM

THE HON'BLE MR.JUSTICE SENTHILKUMAR RAMAMOORTHY

W.P.(MD) No.28730 of 2026

{CNR: HCMD011360412026}

and

W.M.P.(MD) Nos.21808 & 21809 of 2026

Case QR

Tvl.S.G.Fab,

SF.No.251/1,

Seventhilingam Pillayar Road,

Valavanthankottai,

Thuvakudi, Tiruchirappalli - 620 015.

... Petitioner

Vs.

The Assistant Commissioner (ST),

Tiruverumbur Assessment Circle,

Commercial Taxes Department,

Tiruchirappalli.

... Respondent

Prayer : Writ Petition filed under Article 226 of the Constitution of India, for issuance of a Writ of Certiorarified Mandamus to call for the records of impugned order GSTIN: 33ABMFS1350E1ZG/2017-18, dated 05.02.2026

passed by the respondent and quash the same as illegal, erroneous on facts and consequently direct the respondent to rectify the error of Financial/Assessment Year 2019-2020 instead of 2017-2018 in the summary Form GST DRC-08 dated 22.01.2025.

W.P.(MD) No.28730 of 2026

For Petitioner

: Mr.R.Sureshkumar

For Respondent

: Ms.P.Sudarkodi Natchiyar

Government Advocate (Taxes)

*****

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O R D E R

In relation to detailed order dated 19.08.2024, the petitioner applied for rectification. Pursuant thereto, rectification order dated 22.01.2025 was issued dropping the proposal after recognising that the petitioner had availed of and utilised eligible input tax credit. The accompanying summary rectification order, however, directed the petitioner to make payment. Therefore, the petitioner requested that the said order be rectified. The request for rectification was rejected by the order impugned herein.

2. Ms.P.Sudarkodi Natchiyar, learned Government Advocate (Taxes), accepts notice for the respondent.

3. On perusal of the order dated 19.08.2024 and the rectification order dated 22.01.2025, it appears that the petitioner's request for rectification was accepted by recognising that the taxpayer had availed of input tax credit on inward supplies as per GSTR-2A. The summary rectification order, however, is not in conformity with the detailed rectification order. This

W.P.(MD) No.28730 of 2026 appears to have necessitated the filing of a further rectification application. The said application was rejected summarily. Annexure thereto merely records that there is no error apparent on the face of the record. For the reasons discussed earlier, this approach cannot be countenanced in the facts and circumstances. Hence, reconsideration is warranted. Towards that end, the impugned order is set aside and the matter is remanded for reconsideration. After providing a reasonable opportunity to the petitioner, a fresh order shall be issued within three months from the date of receipt of a copy of this order.

4. This Writ Petition is disposed of on the above terms. There shall be no order as to costs. Consequently, the connected Miscellaneous Petitions are closed. 06.10.2026 JEN NCC : No Index : No To The Assistant Commissioner (ST), Tiruverumbur Assessment Circle, Commercial Taxes Department, Tiruchirappalli.

W.P.(MD) No.28730 of 2026 SENTHILKUMAR RAMAMOORTHY, J. JEN W.P.(MD) No.28730 of 2026 06.10.2026

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