Tvl.Vishagan Traders Vs Deputy State Tax Officer (Madras High Court)
The Madras High Court disposed of a writ petition challenging two orders dated 28.11.2025 and 08.12.2025 passed by the tax authorities concerning a discrepancy between Form GSTR-2A and Form GSTR-3B. The petitioner submitted that the first order dated 28.11.2025 quantified the disputed tax amount at ₹87,524 on the issue of mismatch between GSTR-2A and GSTR-3B. Subsequently, another show cause notice dated 21.08.2025 was issued and a second order dated 08.12.2025 was passed addressing two issues, one of which related to the same GSTR-2A and GSTR-3B mismatch that had already been dealt with in the earlier order. In the second order, the disputed tax amount for the same issue was quantified at ₹89,134. The petitioner argued that this resulted in duplication of proceedings and double taxation.
With regard to the second order dated 08.12.2025, the petitioner stated that notices and communications had been uploaded on the GST portal, but they were unaware of them and therefore did not file a reply. As a result, the order was passed without providing an opportunity for personal hearing. The petitioner expressed willingness to pay 25% of the disputed tax amount under the second order and sought an opportunity to present their case before the authority.
