Madras High Court
WP(MD)/30756/2026 of M/s. Reliable Fire Protection Engineers Vs The State of Tamil Nadu on 30 October 2026
WP(MD) No. 30756 of 2026
BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT
DATED: 30-10-2026
CORAM
THE HON'BLE MR. JUSTICE SENTHILKUMAR
RAMAMOORTHY
WP(MD) No. 30756 of 2026
CNR:{HCMD011517472026}
AND
M/s. Reliable Fire Protection Engineers
Rep by its Proprietor M.Pulanthiran,
S/o.Muniraj,
No.402, Vayapuri Nagar, 2nd Cross,
Karur 639 002
..Petitioner(s)
Vs
1. The State of Tamil Nadu
Rep. by its Secretary,
Commercial Taxes and Registration Department, Secretariat, Chennai 600 009
2. The Commissioner of Commercial Taxes
Office of Commissioner of Commercial Taxes, Chennai 600 035
3. The Deputy State Tax Officer 2,
Karur 3 Assessment Circle,
Karur
..Respondent(s)
PRAYER: Writ Petition, filed under Article 226 of the Constitution of India, praying this court to issue a Writ of Certiorarified Mandamus calling for the records pertaining to the impugned order dated 24.12.2025
in GSTIN 33BQXPP8719H2Z1/2021-22 passed by the 3rd respondent __________
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WP(MD) No. 30756 of 2026
and quash the same as illegal and arbitrary and the same has been passed without considering the earlier proceedings wherein the very same issue had already been considered and the proposed demand had been dropped, and consequently direct the 3rd respondents to drop the Demand the money and all consequential recovery proceedings from the petitioner.
For Petitioner(s)
:Mr.M.Shakulhameed
For Respondent(s)
:Mr.R.Parthiban
Special Government Pleader
ORDER
Order dated 24.12.2025 imposing liability on the petitioner in relation to output tax discrepancies is challenged in this Writ Petition.
2. Relying on earlier order dated 15.05.2023 dropping proceedings in relation to the mismatch between the petitioner’s GSTR-01 and GSTR- 3B Returns, learned counsel for the petitioner submits that said dropping order was issued after accepting credit notes of the value of Rs.17,02,767/-. He contends that the same credit notes form subject of the impugned order dated 24.12.2025.
3. Mr.R.Parthiban, learned Special Government Pleader, accepts notice for the respondents. __________
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WP(MD) No. 30756 of 2026
4. Comparing order dated 15.05.2023 with order dated 24.12.2025, two aspects are noticeable. First, both orders relate to assessment period 2021-22. Secondly, both orders dealt with output tax discrepancies. In earlier order dated 15.05.2023, after noticing that the petitioner had issued credit notes of the value of Rs.17,02,767/-, proceedings were dropped by accepting that the mismatch between total turnover reported in GSTR-01 and GSTR-3B is duly explained by the credit notes. Because the same issue relating to the same assessment period is sought to be resurrected in the impugned order, said order is unsustainable and is hereby set aside.
5. This Writ Petition is disposed of on these terms. There shall be no order as to costs. Consequently, connected miscellaneous petitions are closed. 30-10-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No apd __________
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WP(MD) No. 30756 of 2026 To
1. The Secretary, Commercial Taxes and Registration Department Secretariat Chennai 600 009
2. The Commissioner of Commercial Taxes Office of Commissioner of Commercial Taxes, Chennai 600 035
3. The Deputy State Tax Officer 2 Karur 3 Assessment Circle Karur __________
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WP(MD) No. 30756 of 2026 SENTHILKUMAR RAMAMOORTHY, J. apd WP(MD) No. 30756 of 2026 AND
30-10-2026 __________
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