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2026 Supreme(Online)(Mad) 6008

IN THE HIGH COURT OF JUDICATURE AT MADRAS
HONOURABLE MR. JUSTICE KRISHNAN RAMASAMY
Dhanalakshmi Srinivasan Char – Appellant
Versus
The Commercial Tax Officer – Respondent



##PAGE1##

W.P.(MD)Nos.1932 to 1937 of 2026

BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT

DATED : 29.01.2026

CORAM

THE HONOURABLE MR.JUSTICE KRISHNAN RAMASAMY

W.P.(MD)Nos.1932 to 1937 of 2026

& W.M.P(MD)Nos.1521, 1522, 1556, 1560, 1531,

1532, 1523, 15241542, 1545, 1543 &1 544 of 2026

Dhanalakshmi Srinivasan Charitable and Educational Trust

Represented by its Trustee and Vice Chairman

Kathiravan Srinivasan

274C, Siruvachur, Thuraiyur Road

Perambalur - 621 212.

... Petitioner in all petitions

Vs.

1. The Commercial Tax Officer

State Tax Officer – V (Roving Squad)

O/o. The Joint Commissioner (ST) (Intelligence)

Trichy Division, C/107, B3-II Floor

North East Extension, Sastri Road

Thillai Nagar, Trichy - 620 018.

2. The Commercial Tax Officer

State Tax Officer – IV (Inspection)

O/o. The Joint Commissioner (ST) (Intelligence)

Trichy Division, First Floor

No.107 B2, Thillai Nagar

North East Extension, Trichy - 620 018.

... Respondents in all petitions

Common Prayer:

Writ Petition filed under Article 226 of the Constitution of India

praying to issue a Writ of Certiorarified Mandamus,

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##PAGE2##

W.P.(MD)Nos.1932 to 1937 of 2026

calling for the records in GSTIN 33AAATD4216B1ZJ/2018-19

dated 29.12.2025 u/s.74 of the TNGST Act 2017 along with a Summary

of order in Reference No.ZD331225429722K dated 29.12.2025 on the

file of the 2nd Respondent for the period April, 2018 to March 2019 and

quash the same.

calling for the records in GSTIN 33AAATD4216B1ZJ/2019-20

dated 14.11.2025 u/s.74 of the TNGST Act 2017 along with a Summary

of order in Reference No.ZD331125253542Q dated 14.11.2025 on the

file of the 2nd Respondent for the period April, 2019 to March 2020 and

quash the same

calling for the records in GSTIN .33AAATD4216B1ZJ/2020-2021

dated 14.11.2025 u/s.74 of the TNGST Act 2017 along with a Summary

of order in Reference No. ZD3311252539981 dated 14.11.2025 on the

file of the 2nd Respondent for the period April, 2020 to March 2021 and

quash the same

calling for the records in GSTIN 33AAATD4216B1ZJ/2021-22

dated 14.11.2025 u/s.74 of the TNGST Act 2017 along with a Summary

of order in Reference No.ZD331125254708D dated 14.11.2025 on the

file of the 2nd Respondent for the period April, 2021 to March 2022 and

quash the same

calling for the records in GSTIN 33AAATD4216B1ZJ/2022-23

dated 14.11.2025 u/s.74 of the TNGST Act 2017 along with a Summary

of order in Reference No.ZD331125254991E dated 14.11.2025 on the

file of the 2nd Respondent for the period April, 2022 to March 2023 and

quash the same

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##PAGE3##

W.P.(MD)Nos.1932 to 1937 of 2026

calling for the records in GSTIN No.

33AAATD4216B1Z3/2023-24 dated 14.11.2025 u/s.74 of the TNGST

Act 2017 along with a Summary of order in Reference No.

ZD331125255756B dated 14.11.2025 on the file of the 2nd Respondent

for the period April, 2023 to March 2024 and quash the same

For Petitioner

in all petitions : Mr.P.M.Kathir, for Mr.G.Baskar

For Respondents

in all petitions : Mr.R.Suresh Kumar, AGP

COMMON ORDER

These writ petitions have been filed challenging the impugned

orders dated 29.12.2025 & 14.11.2025 passed by the 2nd respondent.

2. Mr.R.Suresh Kumar, learned Additional Government Pleader,

takes notice on behalf of the respondents in all the cases.

3. By consent of the parties, the main petitions are taken up for

disposal at the stage of admission itself.

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##PAGE4##

W.P.(MD)Nos.1932 to 1937 of 2026

4. The learned counsel for the petitioner would submit that in

these cases, the show cause notice was issued by the respondent by

wrongly invoking the provisions of Section 74 of the GST Act, 2017 and

subsequently, the impugned orders were passed without satisfying the

ingredients stated in the said provisions, viz., fraud, wilful-misstatement

or suppression of facts to evade tax, etc.

5. Further, by referring the ultimate findings of the 2nd respondent,

wherein it h

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