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₹1.5 Crore GST Composition Threshold Effective From 01.04.2019: Madras HC

Case Law Details

TaxGuru Citation
2026 taxguru.in 14142
Case Name
Tvl. Sahayarani Medicals Vs Assistant Commissioner (ST) (Madras High Court)
Date of Judgement/Order
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Tvl. Sahayarani Medicals Vs Assistant Commissioner (ST) (Madras High Court)

Summary: The Madras High Court considered a writ petition challenging an assessment order dated 30.12.2025 confirming GST demand along with interest and penalty. The petitioner, Tvl. Sahayarani Medicals, contended that it had remained under the composition scheme and was eligible to discharge tax at the compounded rate under Section 10 of the CGST Act, 2017. It relied upon Notification No. 02/2019-Central Tax dated 29.01.2019 to contend that the enhanced composition threshold was available from 01.02.2019.

The High Court rejected this contention. It observed that Notification No. 02/2019-Central Tax merely brought specified provisions of the CGST (Amendment) Act, 2018 into force from 01.02.2019. The actual enhancement of the turnover threshold for the composition scheme to ₹1.50 crore was implemented through Notification No. 14/2019-Central Tax dated 07.03.2019, which became effective only from 01.04.2019. Consequently, the petitioner could claim the benefit of the enhanced threshold only for the succeeding tax period commencing on 01.04.2019.

Although the Court found the writ petition devoid of merit on this contention, it took note of the petitioner’s undertaking to deposit 25% of the disputed tax and observed that the petitioner might have a case on merits regarding the ultimate tax liability. Accordingly, liberty was granted to file an appeal before the Appellate Authority, subject to depositing 25% of the disputed tax in cash through the Electronic Cash Register within 30 days from receipt of the order.

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Author Info

CA Sandeep Kanoi
Qualification: CA in Job / Business
Company: Taxguru Consultancy
Location: Mumbai, Maharashtra
Articles Published: 20,897

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