IN THE HIGH COURT OF JUDICATURE AT MADRAS

DATED : 03.12.2025

CORAM :

THE HONOURABLE MR.JUSTICE C.SARAVANAN

and

W.M.P.Nos.29944, 29945, 29946, 29947, 29949, 29950, 29964, 29965,

29968 & 29969 of 2025

M/s. K.N.Raj Constructions, Rep.by its Managing Partner,

Sri.N.Santhamoorthy,

No.301, Periyar Nagar,

Kattiganapalli, Krishnagir – 635 001.

... Petitioner in all WPs

Vs.

The State Tax Officer,

Inspection Cell – 3

O/o The Joint Commissioner (ST) (Int),

No.3/47, Sapthagiri Complex,

Hosur Division, Hosur.

... Respondent in all WPs

Prayer in W.P.No.26637 of 2025: Writ Petition filed under Article 226 of the Constitution of India, for issuance of a Writ of Certiorari calling for the records of the respondent in his proceeding in GSTIN/YEAR: 33AAQFK3022J1ZE/2017-18 dated 08.11.2024 and the consequential rectified order in GSTIN/YEAR:33AAQFK3022J1ZE/2017-18 dated

11/11/2024 and quash the same.

Prayer in W.P.No.26639 of 2025: Writ Petition filed under Article 226 of the Constitution of India, for issuance of a Writ of Certiorari calling for the records of the respondent in his proceeding in GSTIN/YEAR: 33AAQFK3022J1ZE/2018-19 dated 08.11.2024 and the consequential rectified order in GSTIN/YEAR:33AAQFK3022J1ZE/2018-19 dated

11/11/2024 and quash the same.

Prayer in W.P.No.26643 of 2025: Writ Petition filed under Article 226 of the Constitution of India, for issuance of a Writ of Certiorari calling for the records of the respondent in his proceeding in GSTIN/YEAR: 33AAQFK3022J1ZE/2019-20 dated 08.11.2024 and the consequential rectified order in GSTIN/YEAR:33AAQFK3022J1ZE/2019-20 dated

11/11/2024 and quash the same.

Prayer in W.P.No.26651 of 2025: Writ Petition filed under Article 226 of the Constitution of India, for issuance of a Writ of Certiorari calling for the records of the respondent in his proceeding in GSTIN/YEAR: 33AAQFK3022J1ZE/2020-21 dated 08.11.2024 and the consequential rectified order in GSTIN/YEAR:33AAQFK3022J1ZE/2020-21 dated

11/11/2024 and quash the same.

Prayer in W.P.No.26653 of 2025: Writ Petition filed under Article 226 of the Constitution of India, for issuance of a Writ of Certiorari calling for the records of the respondent in his proceeding in GSTIN/YEAR: 33AAQFK3022J1ZE/2021-22 dated 08.11.2024 and the consequential rectified order in GSTIN/YEAR:33AAQFK3022J1ZE/2021-22 dated

11/11/2024 and quash the same.

For Petitioner : Mr.B.Raveendran in all WPs For Respondent : Mr.V. Prashanth Kiran Government Advocate in all WPs

COMMON ORDER

These cases were heard twice, once at the time of the admission, and again today. All these writ petitions are being disposed of by this common order.

2. In these writ petitions, the petitioner has challenged the assessment orders in DRC-07 dated 08.11.2024 passed for the respective tax periods by the respondent under Section 74 of the respective GST enactments, as modified by the orders dated 11.11.2024.

3. This is the second round of litigation before this Court. Earlier, the petitioner had suffered adverse assessment orders in respect of the re assessment years on 13.09.2023. Even prior to the aforesaid orders, a sum of Rs.1,42,33,484/- was recovered / paid directly from the petitioner’s bank account on 30.01.2023 towards the tax liability.

4. In this background, by a common order dated 21.08.2024 in W.P.Nos.14865, 14869, 14873, 14875 & 14877 of 2024, wherein these aforesaid assessment orders were challenged, the following order was passed:-

“11. For the reasons stated above, this Court is inclined to set aside the impugned orders dated 13 09 2023 passed by the respondent, with the following directions:-

(i) The orders impugned herein are set aside and the matters are remanded to the respondent in respect of the assessment years 2017-2018, 2018-2019, 2019-2020, 2020-2021 and 2021-2022 for fresh consideration within a period of four weeks from the date of receipt of a copy of this order Since a sum of Rs.1.45 crores was withdrawn from the petitioner's Bank account, this Court is not inclined to impose any further condition