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2026 Supreme(Online)(Mad) 36189

IN THE HIGH COURT OF JUDICATURE AT MADRAS
D.Bharatha Chakravarthy, J
M/s Paper Corporation – Appellant
Versus
Assistant Commissioner, Circle III, Commercial Tax Department – Respondent


Advocates:
For the Petitioner: M/s.A.Lakshmi for M/s.Polax Legal Solutions
For the Respondent: Mr.R.Suresh Kumar Additional Government Pleader

Table of Content
1. discrepancy in gstr-2a amounts overlooked by authority. (Para 2)
2. exemption claim lacked justification per respondent. (Para 3)
3. remand for verifying bills and fresh assessment. (Para 4 , 5)
4. writ allowed, orders set aside, matter remanded. (Para 6)

O R D E R

This Writ Petition is filed challenging the impugned order dated

25.02.2026 passed on the rectification application submitted by the petitioner/assessee, seeking rectification of the assessment order dated

08.12.2025.

2. Upon hearing the learned counsel for the petitioner, it is seen that while passing the assessment order, the respondent/assessing authority had concluded that the taxpayer had submitted GSTR-2A copies amounting to Rs.5,59,37,640/-. However, on a perusal of the statement of bills submitted, the learned counsel would submit that it is clear that the actual amount furnished was Rs.6,00,23,262/-. Therefore, when, on the face of it, the difference in amount has been overlooked by the respondent and when a rectification application was filed, the impugned order has been passed by assigning yet another erroneous reason as if the petitioner is challenging the levy itself.

3. The learned Additional Go

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