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IN THE HIGH COURT OF JUDICATURE AT MADRAS
C.SARAVANAN
Radiant Cash Management Services Ltd, Represented by it Chairman & Managing Director – Appellant
Versus
Commercial Tax Officer, Office of the Assistant Commissioner (ST), Pondy Bazaar Assessment Circle, Chennai – Respondent
| Table of Content |
|---|
| 1. jurisdiction of tax notices. (Para 1 , 2 , 3 , 6 , 8) |
| 2. procedural history of tax assessments. (Para 4 , 5 , 7) |
| 3. details and issues raised in the show cause notices. (Para 9 , 10 , 12 , 13 , 14 , 20) |
| 4. arguments against multiple assessments. (Para 17 , 18 , 19 , 33 , 39) |
| 5. judicial interpretation on assessment overlap. (Para 22 , 23 , 24 , 28 , 29) |
| 6. limits of legal precedent in tax matters. (Para 30 , 31 , 32) |
| 7. finality of proceedings under gst. (Para 34 , 48) |
| 8. conclusion of the writ petition. (Para 49 , 50 , 51) |
ORDER :
The Petitioner is before this Court against the impugned Show Cause Notice in FORM GST DRC 01 dated 23.09.2025 issued under Section 73 of the respective GST Enactments by the Respondent for the tax period 2021-2022.
4.The challenge to impugned Show Cause Notice in DRC 01 dated 23.09.2025 is primarily on the ground that earlier an Intimation in FORM GST DRC 01A dated 06.05.2025 was issued for the same tax period i.e., 2021-2022 to the Petitioner.
6.The Petitioner therefore approached this Court in W.P.No.23660 of 2025 against the said Show Cause Notice in FORM GST DRC 01 dated 29.05.2025. Taking note of the facts and circumstances of the case, thi
Multiple Show Cause Notices can exist for the same tax period under GST if they pertain to different subjects, reinforcing the absence of a bar under the GST regulations.
Natural justice is upheld when multiple opportunities to be heard are provided; consolidated orders across tax periods are permissible under CGST law without causing prejudice unless demonstrable har....
Composite show-cause notices covering multiple financial years under CGST/KGST Act are illegal as assessments must pertain to individual years, respecting statutory limitations and ensuring natural j....
The main legal point established in the judgment is the mandatory and imperative nature of the show cause notice requirement under Section 74(1) of the JGST Act and the need for specific charges in t....
Dual proceedings concerning the same subject matter initiated by State GST authorities after Central GST proceedings are barred under Section 6(2)(b) of the CGST Act.
Transactional value under Section 15 of the GST Act must be the decisive element for tax liability, and arbitrary assumptions regarding pricing or profit margins are impermissible.
The court held that composite assessment orders for multiple financial years violate statutory provisions, emphasizing that each period must have a separate assessment to protect registered persons' ....
A Summary of Show Cause Notice cannot replace a proper Show Cause Notice, and failure to provide a hearing violates natural justice principles.
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