IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 27.01.2026 CORAM THE HON'BLE MR.MANINDRA MOHAN SHRIVASTAVA, CHIEF JUSTICE AND THE HON'BLE MR.JUSTICE G.ARUL MURUGAN WP Nos.3709 and 3940 of 2024 M/S.Kader Exports Private Limited (Formerly known as Devi Marine Food Exports Pvt. Ltd)

Having its reg office at Old No.60, New No.30, 28^th Cross Street Indhira Nagar, Chennai, Tamil Nadu 600 020 rep. By its General Manager Accounts : Petitioner Vs

1.Union Of India Ministry of Finance Rep by its Secretary North Block New Delhi-110 001.

2.State Of Tamil Nadu Rep by Secretary Fort St. George, Chennai-600009

3.The Assistant Commissioner (ST) Adyar Assessment Circle, 2nd Floor, Integrated Building for Commercial taxes and Registration Department, Nandanam, Chennai- 600035 : Respondents Prayer: Petition filed under Article 226 of the Constitution of India for issuance of a Writ of Declaration declaring Rule 96B of CGST Rules 2017 corresponding Rule 96B of TNGST Rules, 2017 as being ultra vires the Section 16 of Integrated Goods and Services Tax Act 2017 and being illegal, arbitrary, without authority of law and violative of Article 14 and Article 19(1)

(g) of the Constitution of India.

For Petitioner :