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2026 Supreme(Online)(Mad) 18843

IN THE HIGH COURT OF JUDICATURE AT MADRAS
MR. MANINDRA MOHAN SHRIVASTAVA, CJ, G.ARUL MURUGAN, J
Reliance Jio Infocomm Ltd Rep by its Power of Attorney Holder Kumar Jayaraman – Appellant
Versus
Union of India Through the Secretary, Department of Revenue, Ministry of Finance, North Block, New Delhi – Respondent


Advocates:
For the Appellants/Petitioners: Mr.Arvind P Datar Senior Counsel for Mr.Rahul Unnikrishnan
For the Respondents:Mr.AR.L.Sundaresan Additional Solicitor General of India Assisted by Ms.Revathi Manivannan Senior Standing Counsel for R1 and R3 Mr.Haja Nazirudeen Additional Advocate General Assisted by Mr.V.Prashanth Kiran Government Advocate for R2
Mr.Su.Srinivasan Senior Central Government Standing Counsel for R1 and R3 Mr.S.Raveekumar Government Pleader (Pondy) assisted by Mr.V.Vasantha Kumar Additional Government Pleader (Pondy) for R2

Table of Content
1. factual background of the case (Para 1)

COMMON ORDER

THE CHIEF JUSTICE

In W.P.No.27038 of 2025, the challenge is to the validity of Rule 39(1)(a) of the Central Goods and Services Tax Rules, 2017 and Rule 39(1)(a) of the Tamil Nadu Goods and Services Tax Rules, 2017 in respect of two periods, viz., prior to 01.04.2025 and thereafter, as 01.04.2025 is the date on which the amendments to Section 20 of the Central Goods and Services Tax Act, 2017 and the Tamil Nadu Goods and Services Tax Act, 2017 were brought into effect. The petitioner also sought quashment of the show cause notice dated 27.6.2025.

2. In W.P.No.28371 of 2025, the petitioner calls into question the validity of Rule 39(1)(a) of the Central Goods and Services Tax Rules, 2017 and Rule 39(1)(a) of the Puducherry Goods and Services Tax Rules, 2017 in respect of two periods, viz., prior to 01.04.2025 and thereafter, as 01.04.2025 is the date on which the amendments to Section 20 of the Central Goods and Services Tax Act, 2017 and the Puducherry Goods and Services Tax Act, 2017 were brought into effect. The petitioner also prayed for setting aside the show cause notice dated 26.6.2025.

3. As the provisions und

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