Tvl.M.Reddiapatti Industries Sales Society Vs Deputy State Tax Officer- 1 (Madras High Court)
The Madras High Court on June 26, 2025, dismissed a writ petition filed by Tvl. M. Reddiapatti Industries Sales Society challenging a GST assessment order dated January 2, 2024, for the Assessment Year 2020-21. The Court’s decision was based on two primary grounds: laches and the petitioner’s admission of tax liability.
The Court noted the petition was filed beyond the statutory period prescribed under Section 117 of the TNGST Act. More critically, the assessment order referenced the petitioner’s online reply dated February 6, 2023, where the taxpayer reportedly “accepted the defect and declared that CGST Rs.1,25,659.57 + SGST Rs. 1,25,659.57 is to be paid.” This admission stemmed from a mismatch between turnover reported in GSTR 1 and GSTR 3B, leading to a lesser tax payment. Despite the petitioner claiming no copy of this reply, the Court held that the admission of liability in the official record negated the challenge. No specific judicial precedents were cited, but the ruling aligns with principles of estoppel and administrative finality when taxpayers concede liability.
FULL TEXT OF THE JUDGMENT/ORDER OF MADRAS HIGH COURT
The petitioner has challenged the impugned assessment order on the file of respondent vide GSTIN.33BOOPS9469G1Z5/2020-21 dated 02.01.2024 as long after it was passed.
