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IN THE HIGH COURT OF JUDICATURE AT MADRAS Reserved on : 16-09-2026 Pronounced on : 28-10-2026 CORAM THE HON'BLE MR.JUSTICE N.SENTHILKUMAR WP Nos.30908, 31022, 31026 & 31597 of 2024 and WMP Nos. 33490, 33645, 33635 & 34347 of 2024 CNR:{HCMA011899812024}

M/s.Aruna Mills Represented by its Managing Partner Mr.E.Rubesh Kumar

46B, Kovai Road Velagoundapalayam, Vellakovil, Kangayam (T.K)

Tiruppur- 638 111.

..Petitioners in all cases Vs

1.The State Tax Officer Inspection Group-1, Office of the Joint Commissioner (ST)

Tirupur Intelligence Division, 5/147, AEPC Building, Kaikattipudur, Tirupur Main Road, Avinashi-641

654.

2.The State Tax Officer (Intelligence)

Inspection Group-V Office of the Joint Commissioner (ST)

Tirupur Intelligence Division

5/147, AEPC Building, KaikattiPudur Tiruppur Main Road Avinashi- 641 654 ..Respondents in all cases Prayer in W.P.No.30908 of 2024: Writ Petition filed under Section 226 of the Constitution of India, seeking to issue a Writ of Certiorarified Mandamus, calling for the records leading to the issuance of order of acceptance bearing reference No.33ABSFA3372JIZ7/ 2022-23 dated 27.03.2024 passed by the First Respondent herein and quash the same, and direct the Respondents herein to refund an amount of Rs.3,84,871/- (IGST-Rs.4,301/- Plus CGST - 1,90,285 +

SGST - 1,90,285) recovered during surprise inspection.

Prayer in W.P.No.31022 of 2024: Writ Petition filed under Section 226 of the Constitution of India, seeking to issue a Writ of Certiorarified Mandamus, calling for the records leading to the issuance of order of acceptance bearing reference no.33ABSFA3372JLZ7 l/2020-21 dated 27.03.2024 passed by the First Respondent herein and quash the same, and direct the Respondents herein to refund an amount of Rs.2,20,09,106/- (IGST - Rs.9,90,000 + CGST -

Rs.1,05,09,553 + SGST Rs.1,05,09,553) recovered during surprise inspection.

Prayer in W.P.No.31026 of 2024: Writ Petition filed under Section 226 of the Constitution of India, seeking to issue a Writ of Certiorarified Mandamus, calling for the records leading to the issuance of order of acceptance bearing reference no.33ABSFA3372JlZ7 l/2021-22 dated 27.03.2024 passed by the First Respondent herein and quash the same, and direct the Respondents herein to refund an amount of Rs.2,59,151/- (IGST - Rs.42,323 + CGST - 1,08,414 +

SGST- 1,08,414) recovered during surprise inspection.

Prayer in W.P.No.31597 of 2024: Writ Petition filed under Section 226 of the Constitution of India, seeking to issue a Writ of Certiorarified Mandamus, calling for the records leading to the issuance of order of acceptance bearing reference no.33ABSFA3372J1Z7 /2023-24 dated 27.03.2024 passed by the First Respondent herein and quash the same, and direct the Respondents herein to refund an amount of Rs.1,40,687 /- (IGST .Rs.36,001 + CGST - 52,343 + SGST - 52,343) recovered during surprise inspection.

In all W.Ps.

For Petitioner: Ms.S.P.Sri Harini For Respondents: Mr.R.Sethu Prabakaran, Government Advocate (Taxes)

COMMON ORDER

These Writ Petitions have been filed to quash the orders dated 27.03.2024 in reference No.33ABSFA3372JIZ7/2020-21, 33ABSFA3372JIZ7/2021-22, 33ABSFA3372JI Z7 2022-23 and 33ABSFA3372JIZ7/2023-24 passed by the first Respondent and seeking a direction to the Respondents to refund the amounts remitted under IGST, CGST and SGST during surprise inspection.

2. The case of the petitioner is as follows:

The petitioner is a proprietary concern represented by its Managing Partner engaged in the manufacture and supply of Cotton yarn and Poly-cotton yarn and synthetic fibres and is registered under GSTIN:33ABSFA3372J1Z7. The petitioner was originally constituted as a proprietorship concern and thereafter it was reconstituted as a partnership firm comprising the Managing partner and his grand father, one Sadhasivam, by way of a partnership deed, dated 28.08.2020. On the retirement of the said Sadhasivam from the partnership firm, Mrs.E.Aruna, the mother of the Managing