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2026 Supreme(Online)(Mad) 29794

IN THE HIGH COURT OF JUDICATURE AT MADRAS
C.SARAVANAN, J
Tvl.Dhanshika Infrastructure Private Limited, Represented by its Manager M.Dhanush – Appellant
Versus
The Assistant Commissioner, Ambattur Assessment Circle – Respondent


Advocates:
For Petitioner: Mr.J.Arun Kumar
For Respondent: Mr.C.Harsharaj Special Government Pleader

Table of Content
1. petitioner's reply requested tax instalments. (Para 2)
2. only commissioner empowered for section 80 instalments; no natural justice breach. (Para 3 , 4)
3. petition dismissed with liberty for fresh application and pre-deposit. (Para 5 , 6)

ORDER

The Petitioner is before this Court against the impugned order dated 25.10.2025 whereby the proposal in the Show Cause Notice in GST DRC-01 dated 10.07.2025 has been confirmed.

2. The Petitioner had also replied to the above Show Cause Notice on 23.08.2025 which is captured in Form GST DRC-06. Relevant portion of the reply of the Petitioner has been extracted below:-

“We humbly request your permission to allow us to discharge the tax liability in instalments under the provisions of Section 80 of the CGST Act . This will enable us to fulfil our obligations in a structured and timely manner while ensuring that our business sustains itself and continues to generate revenue, which in turn contributes to regular tax payments.”

3. A reading of the above reply indicates that the Petitioner attempted to discharge the tax liability however wanted the Respondent Assistant Commissioner to exercise the power under Section 80 of the re

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