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High Courts

High Court of Madras

Rulings of the High Court of Madras, newest first.

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Outcome

In favour of assessee457 In favour of revenue176 Partly allowed0 Matter remanded126

Topic

Demands & adjudication150 Appeals to Appellate Authority69 Input tax credit68 Registration58 Penalty & confiscation33 Refund33 Service of notices & orders30 Appeals to Appellate Tribunal22 Anti-profiteering20 Arrest & bail16 Interest & waiver14 Levy & collection14 Recovery & attachment14 Supply & valuation14 Assessment13 Detention in transit12 Exemptions12 Government contractors11 Offences & prosecution11 Classification & rate9 Returns9 Officers & jurisdiction7 Search & seizure7 Transitional provisions5 Advance ruling3 Cess3 Writs & constitutional remedies3 Rectification2 Other8

Provision

CGST S.73
CGST S.74
CGST S.107
CGST S.75
CGST S.16
CGST S.169
CGST S.29
CGST S.54
CGST S.9
CGST S.30

More provisions

Decision date

FromTo

85 rulings

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Madras High Court8 Jun 2026
For revenue
Tvl. K.Ezhil Arasan, Contractor v. Joint Commissioner (ST) Intelligence
Where petitioner challenged demand orders confirming tax, interest and penalty after issuing SCNs citing discrepancies between GSTR-9 and Form 26AS and GSTR-7 and GSTR-3B and alleging willful suppression under Section 74 while petitioner's replies failed to effectively rebut those allegations, invocation of Section 74 for levying penalty based on prima facie material from inspection records was valid and could not be assailed. GST: Where revenue quantified tax demand by erroneously treating exempted turnover as taxable and adopting figures from wrong period, quantification of demand was vitiated, necessitating reconsideration on merits after giving due opportunity to petitioner; thus, matter was to be remitted for fresh adjudication
- CGST S.74

Madras High Court8 Jun 2026

For revenueRemanded

Ace Tech Heavy Fab (P.) Ltd. v. State Tax Officer

Where petitioner failed to respond to requests for information and show cause notices regarding possible non-payment, short payment, erroneous refund, or wrongful ITC, non-response amounted to suppression to evade tax, justifying invocation of extended limitation and initiation of proceedings under Section 74; hence ex parte orders were warranted in absence of substantive reply, but matter remitted for de novo adjudication. GST: Where DRC-01A intimations and notices were issued for tax periods 2018-2019 and 2019-2020 after scrutiny and no replies were filed, ex parte orders confirming proposals were within limitation under Sections 73 and 74, and Appellate Authority could convert to Section 73 proceedings if Section 74 was wrongly invoked, provided proper reply to DRC-01 was available

CGST S.74
CGST S.73

Madras High Court8 Jun 2026

For assesseeRemanded

Sampoornam v. Assistant Commissioner (ST) (FAC) / Commercial Tax Officer

Where notices and ex parte orders for ITC mismatch and delayed GSTR-9 were issued in name of deceased individual due to non-intimation of death by legal heir, orders were set aside and matter remitted for fresh decision on merits with pre-deposit, as ex parte adjudication was improper despite extended-period provision being validly invoked in present context. GST: Where demands were raised for 2017-2018 and 2019-2020 by issuing DRC-01A and DRC-01, and limitation periods stood extended due to statutory notifications and Supreme Court’s Covid-19 orders, adjudication under general demand provision remained maintainable even if extended- period proceedings were inapplicable, as law permitted passing of orders under general demand provision in such circumstances. GST: Where assessee died and no intimation of death was given, statutory liability for tax, interest or penalty determined against deceased for ITC mismatch and late fee continued upon legal heir, who was required to discharge such liabilities even if business was discontinued, as legal heir is responsible for dues of deceased under GST law

CGST S.74
CGST S.93
CGST S.75
CGST S.73
+1

Madras High Court8 Jun 2026

For revenue

Sameera Hotels (Chennai) (P.) Ltd. v. State Tax Officer (Inspection-I)

Where assessee availed and utilized excess ITC over GSTR-2A figures and failed to pay reverse charge tax on foreign agency commissions, such acts constituted wrongful availment and suppression with intent to evade tax, justifying invocation of extended limitation under Section 74 GST: Orders passed in November 2024 under Section 73 for AYs 2018-19 and 2019-20 were within limitation, as statutory extensions governed computation of time, and limitation issue stood concluded by binding precedent

CGST S.74
CGST S.73
CGST S.75

Madras High Court8 Jun 2026

For revenue

Sunil Kumar Reddy Dontireddy v. Superintendent of CGST

Where audit culminated in show cause notices and single orders-in-original covering multiple assessment years for determination of demands, objection to bunching multiple tax periods in a single proceeding was unsustainable in view of order passed in Chimney Hills Education Society v. Additional Commissioner of

CGST S.74

Madras High Court8 Jun 2026

For assesseeRemanded

Neeyamo Enterprise Solutions (P.) Ltd. v. Commercial Tax Officer

Where SEZ unit's supplies and services for authorised operations were treated as not zero-rated due to non-production of Letter of Undertaking and SEZ Certificate, but required documents were offered for verification during proceedings, adjudication orders were set aside and matter remanded to enable submission and verification of such documents as per Section 16 of IGST Act

IGST S.16
CGST Rules R.96A

Madras High Court8 Jun 2026

For assessee

Tvl. Daisyrani Eng. Constructions v. Superintendent of GST and Central Excise

Where rejection of ITC was based on limitation period before insertion of section 16(5) which provided statutory relaxation on time limit for returns and rectification, subsequent change in law meant old basis of rejection no longer applied, so ITC denial based on pre-amendment position could not be sustained and impugned order was set aside

CGST S.16
CGST S.39

Madras High Court8 Jun 2026

For assesseeRemanded

Zyvana Integrated Services (P.) Ltd. v. Additional Commissioner of GST and Central Excise

Where petitioner disclosed outward supplies in GSTR-1 for certain periods but failed to discharge corresponding output tax through GSTR-3B on time, mere non-receipt of customer payments or lack of intent to evade tax could not alter statutory liability, but in light of section 128A and GST Council deliberations, such short payments warranted reconsideration under section 73 rather than section 74, hence matter required fresh decision accordingly

CGST S.128A
CGST S.73
CGST S.74

Madras High Court8 Jun 2026

For revenue

Tvl. Noyyal Common Effluent Treatment Company Ltd. v. Assistant Commissioner (ST)

Where petitioner initially discharged GST at a lower rate and later paid differential tax after departmental intimation regarding higher tax rate, liability to pay interest for belated tax payment arose under determination and recovery framework, and obligation to pay interest subsisted irrespective of subsequent payment or willingness to pay in instalments, rendering recovery of such interest under determination and recovery provisions fully justified. GST: Where petitioner initially discharged GST at a lower rate and later paid differential tax after departmental intimation regarding higher tax rate, interest on delayed payment remained payable under determination provisions and reference to extended period in DRC-01 and DRC-07 would not invalidate proceedings; matter required reconsideration of petitioner’s reply in light of business nature for a fresh order

CGST S.50
CGST S.75
CGST S.79
CGST S.74
+1

Madras High Court8 Jun 2026

For revenue

Fastenex (P.) Ltd. v. State Tax Officer

Where assessees challenged demands raised invoking extended-period on ground that there was lack of foundational facts in show cause notices, in view of fact that prior communications like scrutiny, audit or inspection had already conveyed requisite reasons and facts, invocation of extended-period was valid; absence of reasons in show cause notice alone was not fatal if jurisdictional facts were discernible from earlier communications or on record, subject to prima facie satisfaction under section 74. GST: Where fraud, wilful misstatement, or suppression is not established, proceedings initiated under Section 74 need not fail but may be converted into Section 73 proceedings; such conversion preserves valid tax demands while excluding consequences dependent on extended-period ingredients. GST: Where central authorities issued consolidated show cause notices spanning multiple years and parties disputed permissibility of such composite notices, consolidated SCNs covering multiple periods were deemed valid, as normal and extended-period demands were not tax-period specific and statute did not prohibit common SCNs for multiple periods GST: Where assessee, on being inspected for multiple years and issued DRC-01A and DRC-01 alleging fraud, non-cooperation, documentation lapses and failures to provide financials, challenged show cause notices as pre-determined, since GST scheme allows communication of reasons throughout proceedings and detailed SCN was intended to enable assessee for rebuttal, writ challenge was not maintainable and merits had to be adjudicated in their own course.…

CGST S.74
CGST S.61
CGST S.65
CGST S.66
+5

Madras High Court8 Jun 2026

For revenue

Southern Steels v. Assistant Commissioner (ST)

Where assessee operated two registrations and department inspection revealed circular transactions and fictitious ITC on non-supplies, such findings prima facie justified invoking extended limitation period under GST for both registrations and challenge to such invocation was untenable as all procedural requirements for Erode registration were duly followed as threshold for invoking extended period under GST regime is lower than previous indirect tax laws GST: Where post-remand DRC-07 orders for Gobichettipalayam were passed without prior DRC-01 show cause notice, such orders were to be set aside for fresh adjudication with opportunity and natural justice, while Erode proceedings that followed proper sequence with DRC-01A and DRC-01 reply suffered no procedural infirmity and were not to be interfered

CGST S.74
CGST S.75
CGST Rules R.142

Madras High Court8 Jun 2026

For revenue

RMZ Infinity (Chennai) (P) Ltd v. Joint Commissioner of CGST & Central Excise, Chennai

ITC on works contracts and construction of immovable property used for renting is blocked under Section 17(5)(d); rented building being not “plant or machinery,” ITC claimed on such construction was rightly denied GST: Prior intimation to department, without statutory approval, does not preclude invocation of extended limitation; where blocked ITC was availed beyond prescribed time and without concurrence, extended period and equal penalty for suppression were rightly invoked despite subsequent reversal of credit. GST : Joint assessment proceedings for multiple tax periods justified; common show cause notice issued for multiple tax periods cannot be challenged

CGST S.17
CGST S.16
CGST S.74

Madras High Court8 Jun 2026

For revenue

Canon India (P.) Ltd. v. State Tax Officer/Group - VI

Where SCNs alleging tax or ITC fraud for periods 2017-2018 to 2019-2020 were issued in Form GST DRC-01 under Section 74 prior to expiry of statutory limitation and after issuance of DRC-01A intimation, challenge on limitation was untenable as statutory timelines were complied with, and SCNs therefore survived. GST: Where petitioner failed to reply to DRC-01A in respect of 2018-2019 and 2019- 2020 leading to non-cooperation and suppression under Explanation-2, invocation of Section 74 machinery was justified and, with disputed facts involved, remedy lay in adjudication by replying to SCNs rather than writ, so writ petitions seeking quash were not maintainable

CGST S.74
CGST S.75
CGST S.73

Madras High Court8 Jun 2026

For revenue

Chemplast Sanmar Ltd. v. Assistant Commissioner (ST)

Where petitioner company was merged and after NCLT's approval, unutilized ITC and liabilities were transferred and department parallelly initiated audit-based and scrutiny-based proceedings for same period, audit and scrutiny notices could be issued separately as each arose from distinct processes; suppression of facts being disclosed as was required for invoking section 74, limitation period would be extended and, thus, SCNs could not be challenged filing writ petitions

CGST S.74
CGST S.44
CGST S.65
CGST S.73
+2

Madras High Court8 Jun 2026

For revenue

Tvl. Technocast Foundry v. State Tax Officer

Where registered manufacturer failed to maintain job-work records or file prescribed Form ITC-04 due to alleged technical issues, and could not prove receipt of goods within timelines, movement was deemed as supply and tax, interest and equal penalty were correctly confirmed, with extended period invocation upheld since exceptions were not attracted and threshold under GST for such invocation was lower GST: Where registered manufacturer sent goods to sister concern for job work but failed to maintain job-work records or file prescribed form, and department treated such transfers as deemed supplies with tax, interest, and penalty, remand for verification was warranted to examine revenue neutrality and onus was on petitioner to establish tax payment by principal or job worker, with adjudication on factual merits to follow

CGST S.74
CGST S.143
CGST Rules R.45

Madras High Court5 Jun 2026

For assesseeRemanded

Tvl. Punitha Antony Store v. State Tax Officer

Where penalty equals to 100 percent of tax was imposed under Section 74 for alleged fraud though penalty only of 50 percent of tax under Section 74A was statutorily leviable, as provisions invoked had led to a higher penalty and materially altered liability, such error was not curable as a mere misquotation; impugned penalty order was to be quashed and fresh proceedings was to be initiated under correct provision

CGST S.74
CGST S.74A
CGST S.160

Madras High Court5 Jun 2026

For revenue

V.V. Iron Steel Company (P.) Ltd. v. Assistant Commissioner, Central GST and Central Excise

Where manufacturer of TMT steel bars had credits blocked under Rule 86A due to evidence that four supplier premises were vacant with no infrastructure, no vehicle movements were recorded for alleged deliveries, and documentation anomalies indicated fake transactions, power to block ITC was validly exercised based on adequate material, and writ seeking unblocking was not justified

CGST Rules R.86A
CGST Rules R.86

Madras High Court5 Jun 2026

For assesseeRemanded

Akal Trade Links v. Assistant Commissioner (ST)

Where petitioner purchased goods under invoices containing vehicle numbers from a registered supplier who filed returns and paid tax, denial of input tax credit solely due to absence of lorry receipts and weighment slips without enquiry into genuineness of supply was unsustainable, thus order confirming denial on that basis was set aside and required reconsideration

CGST S.16
CGST S.155
CGST Rules R.36

Madras High Court3 Jun 2026

For assesseeRemanded

Kay Arr Engineering Services v. Assistant Commissioner of GST & Central Excise

Where DGGI issued SCN and Assistant Commissioner adjudicated and passed OIO confirming proposals, since power to pass orders on DGGI notices was vested only in Additional or Joint Commissioner by Notification 02/2022-CT, OIO passed by Assistant Commissioner suffered procedural irregularity and same was to be was quashed; matter to be decided by competent authority as per prevailing notifications

IGST S.3
CGST S.5

Madras High Court3 Jun 2026

For revenue

MNS Enterprises v. Additional Commissioner of GST and Central Excise

Where registered persons challenged orders assessing liability for fraudulent ITC availed based on a key witness's statement but were denied cross-examination, right to cross-examination was not absolute since allegations pertained to bogus ITC and could be rebutted by documentary evidence, thus, mere denial of cross- examination did not vitiate adjudication, making statutory appeal appropriate remedy

CGST S.74
CGST S.70
CGST S.75

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