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2026 Supreme(Online)(Mad) 39269

IN THE HIGH COURT OF JUDICATURE AT MADRAS
C.SARAVANAN, J
SM Traders – Appellant
Versus
Deputy Commissioner (CT), SGST Appeal – Respondent


Advocates:
For Petitioner: Mr.G.Derrick Sam
For Respondent:Mrs.K.Vasanthamala Government Advocate

Table of Content
1. appeal rejected on limitation under s.107. (Para 2 , 3)
2. pre-deposit made; assessment confirmed on non-reply. (Para 4 , 5 , 6 , 7 , 8)
3. 25% pre-deposit mandated for remand. (Para 9 , 10 , 16 , 17)
4. directions for fresh adjudication and compliance consequences. (Para 11 , 12 , 13 , 14 , 15 , 18)

ORDER

Mrs.K.Vasanthamala, learned Government Advocate takes notice for the Respondent.

2. This Writ Petition is being disposed of at the time of admission with the consent of the learned counsel for the Petitioner and the learned Government Advocate for the Respondent.

3. The Petitioner is before this Court against the impugned Order dated 11.09.2025 whereby the Petitioner’s appeal against the Order dated 29.05.2025 has been rejected as the appeal was filed beyond the limitation period prescribed under Section 107 of the respective GST Enactments.

4. Learned counsel for the Petitioner submits that at the time of filing of appeal before the Appellate Authority herein, the Petitioner has deposited 10% of the disputed tax covered by the order dated 29.05.2025 and the same stands recorded in the impugned Order dated 11.09.2025 in Form GST APL-02.

5. A reading of the Order passed

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