Madras High Court
WP/36652/2026 of M/s.Professional Skill Training and Consultancy Pr Vs Commercial Tax Officer on 21 September 2026
IN THE HIGH COURT OF JUDICATURE AT MADRAS
DATED: 21.09.2026
CORAM
THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY
WP Nos. 36652 and 36664 of 2026
and
W.M.P.Nos.41082, 41085, 41096 and 41097 of 2026
W.P.No.36652 of 2026
CNR:{HCMA012110432026}
M/s.Professional Skill Training and
Consultancy Private Limited,
Represented by its Director Ameen Afzal, 813,2nd Floor, Nizara Bonanza Complex, Mount Road, Chennai- 600 002
..Petitioner
Vs
Commercial Tax Officer,
..Respondent
WP No. 36664 of 2026
CNR:{HCMA012110452026}
M/s.Professional Skill Training and
Consultancy Private Limited,
Represented by its Director Ameen Afzal, 813,2nd Floor, Nizara Bonanza Complex, Mount Road, Chennai- 600 002
..Petitioner
Vs
Commercial Tax Officer,
..Respondent
W.P.No.36652 of 2026: Petition filed under Article 226 of the Constitution of India praying for issuance of Writ of Certiorari calling
for records relating to the impugned order in Form DRC-07 bearing reference ZD330626184163D dated 18.06.2026 along with the detailed order GSTIN 33AAHCP6985B1ZB/2022-2023 dated 18.06.2026 passed by the Respondent and quash the same.
WP No. 36664 of 2026: Petition filed under Article 226 of the Constitution of India praying for issuance of Writ of Certiorari calling for records relating to the impugned order in Form DRC-07 bearing reference ZD330626184333C dated 18.06.2026 along with the detailed order GSTIN 33AAHCP6985B1ZB/2023-2024 dated 18.06.2026 passed by the Respondent and quash the same.
For Petitioner:
Ms.K.Aarthy
in both WPs
For Respondent:
Ms.G.Dhana Madhri,
Special Government Pleader (Tax)
in both WPs
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COMMON ORDER
In these two writ petitions, orders dated 18.06.2026 are challenged both on the ground that the assessment orders travelled beyond the scope of the corresponding show cause notices and on the ground that the petitioner’s replies to the ASMT-10 notices were disregarded.
2. Comparing the show cause notices with impugned orders, learned counsel for the petitioner submits that the total tax demand under the show cause notice pertaining to assessment period 2022-2023 was about Rs.71 lakhs, whereas the confirmed tax demand under the corresponding impugned order is Rs.1,89,10,978/-. She points out that the order relating to assessment period 2023-2024 is vitiated for the same reason. She also submits that petitioner’s replies in course of scrutiny proceedings were disregarded.
3. Ms.G.Dhana Madhri, learned Special Government Pleader (Tax), accepts notice for the respondent. She submits that the respondent may be directed to reconsider the matter.
4. On comparison of show cause notices and the corresponding assessment orders, the contention of learned counsel for the petitioner that the impugned orders travelled beyond the scope of the show cause notices is liable to be accepted. Hence, it is directed that these impugned orders be treated as show cause notices. The petitioner may reply within fifteen days from the date of receipt of a copy of this order. After providing a reasonable opportunity, fresh orders shall be issued within five months from the date of receipt of the petitioner's replies.
5. Both the writ petitions are disposed of on the above terms. Consequently, connected miscellaneous petitions are closed. There shall be no order as to costs. 21.09.2026 Index:Yes/No Neutral Citation:Yes/No mmi/rsm
SENTHILKUMAR RAMAMOORTHY J. mmi To The Commercial Tax Officer,
WP Nos. 36652 and 36664 of 2026 21.09.2026