Tvl.Shriram Finance Ltd. vs State of Tamil Nadu Rep by the Joint Commissioner (CT), Chennai (East) Division, Chennai

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2026 Supreme(Online)(Mad) 25735

IN THE HIGH COURT OF JUDICATURE AT MADRAS
G. Jayachandran, Shamim Ahmed, JJ
Tvl.Shriram Finance Ltd. – Appellant
Versus
State of Tamil Nadu Rep by the Joint Commissioner (CT), Chennai (East) Division, Chennai – Respondent
T.C.(Revision Petition).No. 10 of 2026

Important Points

No substantial question of law arises when issue settled in prior judgments for same assessee and Revenue.

Subject

Taxation - Sales Tax / VAT Revision

Act Referred

Tamil Nadu Value Added Tax Act, 2006: S.60

Headnote

The Tamil Nadu Value Added Tax Act, 2006 governs the proceedings under Section 60(1) for revision petitions. The assessee challenged the Tribunal's order for certain assessment years, following prior decisions on identical issues. The Court found no substantial question of law, relying on previous judgments upholding Revenue's position. The sole issue was whether a substantial question of law arose, given prior rulings for the same parties across different assessment years. The ratio decidendi affirms dismissal by following binding precedents from Tax Case (Revision) Nos.101, 92 of 2025 and T.C.Nos.113, 114 of 2025. Tax Case (Revision) dismissed, affirming the Tribunal's order in favour of Revenue.

Advocates:
For Petitioner(s): Ms.Sivaraman, R P. Ramesh Kumar, Raghav, Rajeev Menon, Gautham Venkatanarayanan
For Respondent(s):Mr.V.Prasanth Kiran, Govt. Advocate (Taxes)

(Order of the Court was made by Dr.G.Jayachandran J.)

The issue that involves in this case, had already been settled in favour of the Revenue for the same assessee for the other assessment years. Therefore, there is no substantial question of law required to be answered in this tax case, in view of the judgment of this Court rendered in T.C.(Revision).No.6 of 2026, dated 05.03.2026 between the same assessee and the State of Tamil Nadu, represented by the Appellate Deputy Commissioner (CT), Chennai (East), wherein, in paragraph 2, it was observed as under: “2. In view of the judgments rendered by this Court in respect of the substantial question of law involved in this matter and in respect of the same parties, but for the different Assessment Years, in Tax Case (Revision) No.101 of 2025, dated 16.10.2025, Tax Case (Revision) No.92 of 2025, dated 23.09.2025 and T.C.Nos.113 and 114 of 2025, dated 10.12.2025, we are of the view that this Tax Case (Revision) has to be dismissed by following the said three judgments of the Division Benches of this Court. Accordingly, the substantial questions of law framed in this case are answered against the assessee and in favour of the Revenue and the present Tax Case (Revision) is dismissed.”

Accordingly, the present Tax Case (Revision) is dismissed.