The determination of seigniorage charges as a supply is pending before the Supreme Court, and prior payments should lead to lifting any bank attachment.

C O M M O N O R D E R

By this common order, both Writ Petitions are being disposed of at the admission stage itself.

2. In these writ petitions, the petitioners have challenged the impugned orders, both dated 12.06.2024, passed for the tax period 2019-2020 and 2020-

2021.

3. By the impugned orders, the proposals made in the notices have been confirmed. Prima facie, the issues involved appear to be pending before the Hon'ble Supreme Court, and all further proceedings have been stayed, awaiting further orders of the Hon'ble Supreme Court. The issue pertains to whether the payment of seigniorage charges constitutes a supply, as it is a right granted in return for consideration in the form of charges collected. The mining contractors are given the right to extract and explore minerals upon payment of seigniorage fees to the Government, as provided under the Mines and Minerals (Development and Regulation) Act, 1957.

4. It is recorded that the petitioner has already paid the amount prior to the passing of the impugned orders. The matter is remitted back to the respondent to pass a fresh order after the Hon'ble Supreme Court decides the issue.

5. These Writ Petitions are disposed of with the above directions.

As the petitioner has already paid the tax and liability, the respondent is directed to instruct the bank that the attachment shall stand automatically lifted. No costs. Consequently, connected W.M.Ps are closed.

10.11.2025 nvi Neutral Citation : Yes / No To:

1.The Assistant Commissioner (ST), Palladam - II Assessment Circle, Palladam, Tiruppur.

2. The Branch Manager, Canara Bank,4/687, Trichy Main Road, Near Bus Stand, Karanampettai, Tiruppur.

C.SARAVANAN, J.