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W.P.No.49575 of 2025

Sl.No Tax Period Tax Interest Penalty Total

1 July 2017 – 5,37,815.00 0.00 5,37,815.00 10,75,630.00

March 2018

2 July 2017 – 4,09,613.00 0.00 4,09,613.00 8,19,226.00

March 2018

3 July 2017 – 4,09,613.00 0.00 0.00 4,09,613.00

March 2018

Total 13,57,041.00 0.00 9,47,428.00 23,04,469.00

5. It is the case of the Petitioner that from and out of the total tax

liability of Rs.13,57,041/- the Petitioner has reversed an amount of

Rs.8,05,443/- partly in the 3B return filed for the tax period 2018 – 2019.

6. The learned counsel for the Petitioner further submits that the

Petitioner is confining the challenge to the impugned order only to the extent

of Rs.4,51,596/-.

7. The learned Government Advocate for the Respondent is

however unable to confirm the same. This would require a detailed

consideration.

8. Following the consistent view taken by this Court under similar

circumstances, the case is remitted back to the Respondent to pass a fresh

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W.P.No.49575 of 2025

order on merits subject to the Petitioner depositing 100% of the admitted tax

demand in cash and confirmed vide order dated 26.12.2023 together with

interest and penalty from the Petitioner's Electronic Cash Register within a

period of thirty (30) days from the date of receipt of a copy of this order. The

Petitioner shall also deposit 100% of disputed tax liability of Rs.4,51,596/-

within such time.

9. Needless to state, any debit purportedly made from the

Petitioner’s Electronic Cash Register for the month of September 2018 for

the aforesaid sum of Rs.8,05,443/-, shall be adjusted towards the pre-deposit

shall be subject to verification.

10. Within such time, the Petitioner shall also file a reply to the

Show Cause Notice in GST DRC-01 dated 26.12.2023 together with requisite

documents to substantiate the case by treating the impugned Order dated

14.11.2024 as an addendum to the Show Cause Notice dated 26.12.2023.

11. In case the Petitioner complies with the above stipulations, the

Respondent shall proceed to pass a final order on merits and in accordance

with law as expeditiously as possible, preferably, within a period of three (3)

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W.P.No.49575 of 2025

months of such reply/pre-deposit. Subject to the Petitioner complying with

the above stipulations and subject to Petitioner not being in arrears of any

other amount barring the amount demanded under the impugned order, the

attachment of the bank account of the Petitioner shall also stand vacated /

lifted.

12. In case the Petitioner fails to comply with any of the

stipulations, the Respondent is at liberty to proceed against the Petitioner to

recover the tax in accordance with law as if this Writ Petition was dismissed

in limine today.

13. Needless to state, before passing any such order, the

Respondent shall give due notice to the Petitioner.

14. This Writ Petition stands disposed of with the above

observations. No costs. Connected Writ Miscellaneous Petitions are closed.

19.12.2025

Neutral Citation: Yes / No

jas

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W.P.No.49575 of 2025

C.SARAVANAN, J.

jas

W.P.No.49575 of 2025

and

W.M.P.Nos.55414 and 55417 of 2025

19.12.2025

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