Madras High Court
WP(MD)/30865/2026 of Tvl. SAKTHI TRADERS Vs The State Tax Officer on 30 October 2026
WP(MD) Nos. 30865 to 30867 of 2026
BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT
DATED: 30-10-2026
CORAM
THE HON'BLE MR. JUSTICE SENTHILKUMAR
RAMAMOORTHY
WP(MD) Nos. 30865 to 30867 of 2026
CNR:{HCMD011501992026}
and
W.M.P.(MD) Nos.23612, 23621 & 23614 of 2026
Tvl. Sakthi Traders
Rep. by its Proprietor, P. Ramachandiran, GSTIN 33DKXPP9854F1ZA, 4/197-1, Madiyanoor Street, Avudaiyanoor, Tenkasi - 627 808.
..Petitioner(s)
Vs
The State Tax Officer
Tenkasi Assessment Circle,
Commercial Taxes Buildings,
Tenkasi.
..Respondent(s)
PRAYER IN W.P(MD)No.30865 of 2026:Writ Petition filed under Article 226 of the Constitution of India, praying this Court to issue a Writ of CERTIORARIFIED MANDAMUS, to call for the records on the file of the respondent in GSTIN 33DKXPP9854F1ZA/2021-22 bearing Reference No. ZD3312253977823 dated 26.12.2025 for the assessment year 2021-22 passed by the Respondent under section 73 of TNGST Act 2017 and to quash the same as cryptic, non-speaking, illegal, arbitrary, wholly without jurisdiction and direct the respondent to pass assessment order.
PRAYER IN W.P(MD)No.30866 of 2026:Writ Petition filed under
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WP(MD) Nos. 30865 to 30867 of 2026
Article 226 of the Constitution of India, praying this Court to issue a Writ of CERTIORARIFIED MANDAMUS, to call for the records on the file of the respondent in GSTIN 33DKXPP9854F1ZA/2021-22 bearing Reference No. ZD3312254457858 dated 30.12.2025 for the assessment year 2021-22 passed by the Respondent under section 73 of TNGST Act 2017 and to quash the same as cryptic, non-speaking, illegal, arbitrary, wholly without jurisdiction and direct the respondent to pass assessment order afresh after affording opportunity of being heard.
PRAYER IN W.P.(MD)No.30867 of 2026:
Writ Petition filed
under Article 226 of the Constitution of India, praying this Court to issue a Writ of Certiorarified Mandamus, to call for the records on the file of the respondent in GSTIN 33DKXPP9854F1ZA /2021-22 bearing Reference No. ZD331225443682I dated 30.12.2025 for the assessment year 2021-22 and to quash the same as illegal, arbitrary, wholly without jurisdiction, and direct the respondent to pass an assessment order afresh after affording a sufficient opportunity within such time as may be directed by this Court.
For Petitioner(s)
:Mr.N.Sudalai Muthu
(in all W.Ps)
For Respondent(s)
:Mr.R.Parthiban
(in all W.Ps)
Special Government Pleader
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WP(MD) Nos. 30865 to 30867 of 2026
COMMON ORDER
These three Writ Petitions pertain to assessment period 2021-22. The issues dealt with therein are the value of exempt supplies, availment of common Input Tax Credit and purchases of cotton from unregistered dealers.
2. Relying on the petitioner’s reply to the Show Cause Notice preceding order dated 30.12.2025, learned counsel for the petitioner submits that the petitioner had provided a breakup between taxable inward supplies and exempt inward supplies and enclosed all relevant documents in that regard. He points out that the order was passed by disregarding the reply. He also adds that the order dated 26.12.2025 and the order dated 30.12.2025 are inconsistent and that these orders are required to be re-adjudicated in a consolidated manner. With regard to the order dated 30.12.2025 forming subject of W.P.(MD) No.30867 of 2026, relating to receipt of goods from unregistered dealers, on instructions, learned counsel submits that the petitioner would remit 25% of the tax demand under said order as a condition for remand. An endorsement to that effect has been made.
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WP(MD) Nos. 30865 to 30867 of 2026
3. As contended by learned counsel for the petitioner, the petitioner has disclosed the total value of exempt supplies as Rs.1,84,85,050/-. Relevant invoices and other documents to establish that the petitioner was dealing in paddy were enclosed with the reply to the Show Cause Notice in W.P.(MD) No.30867 of 2026. Therefore, reconsideration in a consolidated manner is warranted.
4. Even as regards W.P.(MD) No.30867 of 2026, subject to the petitioner remitting 25% of the tax demand under said order, it is necessary to provide another opportunity to the petitioner to contest the matter on merits. Therefore, subject to remittance of 25% of tax under order dated 30.12.2025, which is challenged in W.P.(MD) No.30867 of 2026 within thirty (30) days from the date of receipt of a copy of this order, these three impugned orders are set aside and these matters are remanded to the proper officer for a consolidated adjudication. After providing a reasonable opportunity to the petitioner, a fresh consolidated order shall be issued within five (5) months from the date of remittance in the manner specified above.
5. These Writ Petitions stand disposed of on the above terms. There
WP(MD) Nos. 30865 to 30867 of 2026 shall be no order as to costs. Consequently, the connected miscellaneous petitions are closed. 30-10-2026 Index: Yes/No (2/2) Speaking/Non-speaking order Neutral Citation: Yes/No apd To The State Tax Officer Tenkasi Assessment Circle Commercial Taxes Buildings Tenkasi
WP(MD) Nos. 30865 to 30867 of 2026 SENTHILKUMAR RAMAMOORTHY, J. apd WP(MD) Nos. 30865 to 30867 of 2026 30-10-2026 (2/2)
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