Tvl. Fabro Gaarden Vs State Tax Officer (INT) (Madras High Court)
The Madras High Court recently addressed a case concerning the validity of a manual appeal filed by a taxpayer, Tvl. Fabro Gaarden, whose vehicle and goods were seized for not possessing an e-invoice. The incident occurred on December 4, 2023, and a formal order was issued on October 13, 2024. The taxpayer, unable to access a web copy of the order, filed a manual appeal on January 4, 2025, well within the prescribed time limit. Later, after receiving the web copy, a second appeal was filed on July 21, 2025, which was then rejected as belated by the appellate authority.
The court, after hearing arguments, set aside the appellate authority’s decision. It held that since the taxpayer had already filed a manual appeal in a timely manner, they should not be penalized for the delay in the online system. The matter was remitted back to the appellate authority, with a specific directive to number the original manual appeal and decide on its merits. The court also permitted the petitioner to submit additional evidence, including the e-invoice that was missing during the vehicle’s interception, citing a precedent from the Allahabad High Court in the case of Kumar Cargo Solution Vs. State of U.P. This ruling confirms that a timely manual appeal is valid and that appellate authorities must consider such submissions, along with any relevant additional evidence, before passing a final order.
