Reckitt Benckiser (India) Private Limited Vs State of Tamil Nadu (Madras High Court)
Summary: The Madras High Court disposed of three interconnected writ petitions filed by Reckitt Benckiser (India) Private Limited by a common order dated 24.04.2026. The petitions arose from the same set of facts and concerned the tax period 2019-2020 and challenges connected with the extension of limitation under the GST enactments.
In W.P.No.20655 of 2024, the petitioner challenged the impugned order/reply dated 29.05.2024 relating to the tax period 2019-2020. In W.P.No.20652 of 2024, the petitioner challenged Notification No.9 of 2023-Central Tax dated 31.03.2023 and the consequential Government Orders issued under Section 168A of the respective GST enactments extending the period of limitation. TaxGuru has separately published the text and details of Notification No. 09/2023-Central Tax dated 31.03.2023.
W.P.No.20657 of 2024 concerned the impugned show cause notice dated 31.05.2024 issued in Form GST DRC-01 for the tax period 2019-2020. The reference to Form GST DRC-01 is also addressed in TaxGuru’s publication on electronic submission of GST DRC-01 and DRC-02 summaries.
At the time of admission, the High Court had granted interim protection by order dated 13.08.2024. Pursuant thereto, the jurisdictional State Tax Officer submitted a detailed report dated 27.01.2026. The Court recorded that the conclusion contained in that report prima facie supported the stand of the petitioner.
In view of the subsequent developments and the report dated 27.01.2026, the learned counsel for the petitioner submitted that no further adjudication survived insofar as W.P.No.20657 of 2024 was concerned. The Court accepted that position. It further recorded that the challenge raised in W.P.Nos.20652 and 20655 of 2024 had also become academic.
Accordingly, the Court closed W.P.Nos.20652 and 20655 of 2024 and disposed of W.P.No.20657 of 2024. No costs were awarded, and the connected miscellaneous petition was also closed.
The order therefore does not decide the substantive validity of the challenged limitation-extension notifications or the underlying GST dispute on merits. The disposal followed the subsequent developments and the jurisdictional State Tax Officer’s report, which rendered further adjudication unnecessary in the connected proceedings.
FULL TEXT OF THE JUDGMENT/ORDER OF MADRAS HIGH COURT
Since the issues involved in these writ petitions are interconnected and arise out of the same set of facts, they are taken up together and are disposed of by this common order.
2. In W.P.No.20655 of 2024, the petitioner has challenged the impugned order/reply dated 29.05.2024 relating to the tax period 2019-2020. In W.P.No.20652 of 2024, the petitioner has challenged Notification No.9 of 2023-Central Tax dated 31.03.2023 and the consequential Government Orders issued under Section 168A of the respective GST enactments extending the period of limitation. In W.P.No.20657 of 2024, the petitioner has challenged the impugned show cause notice dated 31.05.2024 issued in Form GST DRC-01 relating to the tax period 2019-2020.
3. The learned counsel for the petitioner submitted that, in view of the subsequent developments and the report submitted by the jurisdictional State Tax Officer pursuant to the orders passed by this Court, no further adjudication survives insofar as W.P.No.20657 of 2024 is concerned.
4. It is seen that, at the time of admission of these writ petitions, this Court, by order dated 13.08.2024, granted interim protection. Pursuant thereto, the jurisdictional State Tax Officer submitted a detailed report dated 27.01.2026. The conclusion contained in the said report prima facie supports the stand of the petitioner.
5. In view of the subsequent developments and the report dated 27.01.2026 submitted by the jurisdictional State Tax Officer, no further adjudication survives insofar as W.P.No.20657 of 2024 is concerned and the challenge raised in W.P.Nos.20652 and 20655 of 2024 has also become academic.
6. Accordingly, W.P.Nos.20652 and 20655 of 2024 are closed and W.P.No.20657 of 2024 is disposed of. No costs. Consequently, connected miscellaneous petitions are closed.
