Facts of the Case
The petitioner, Tvl. Sivasakthi Amman,
represented by its proprietor T. Sermathurai, approached the Madurai
Bench of the Madras High Court under Article 226 of the Constitution of
India.
The petitioner challenged the assessment order
dated 17.12.2025 for Tax Period 2021-22 and sought a Writ of
Certiorarified Mandamus to:
- call for the records relating to the impugned order;
- quash the order as illegal;
- quash it as being without jurisdiction;
- quash it for gross violation of the principles of natural justice;
and
- direct the respondent to redo the assessment afresh after providing
an opportunity of personal hearing in accordance with the GST Act, 2017.
The impugned order was expressly an assessment
order passed under Section 73 of the TNGST Act, 2017.
The assessment was completed ex parte
because the petitioner had not utilised the opportunities provided during the
proceedings.
The detailed three-column table on page 3 of the
judgment identifies two separate discrepancies:
- Input mismatch – GSTR-3B vs GSTR-2A
- ITC to be reversed on non-business transactions and exempted goods
The same table separately records:
- the assessee’s explanation on merits; and
- the explanation for not availing the opportunity.
This page 3 table is central to understanding the
precise scope of the dispute.
Issues
Involved
The principal issues involved were:
- Whether the ex parte assessment order dated 17.12.2025 passed under
Section 73 of the TNGST Act, 2017 could be sustained without
considering the petitioner’s proposed reply and supporting documents.
- Whether there was any actual excess claim of ITC arising from
the mismatch between GSTR-3B and GSTR-2A.
- Whether the petitioner should be permitted to submit connected
records in accordance with Circular No. 183/15/2022 dated 27.12.2022.
- Whether compliance with the said circular would affect the alleged
liability arising from the GSTR-3B vs GSTR-2A mismatch.
- Whether ITC was liable to be reversed on the ground of non-business
transactions.
- Whether ITC was liable to be reversed in relation to exempted
goods.
- Whether the petitioner had in fact claimed ITC only on goods
related to its business.
- Whether the petitioner had maintained taxable goods and exempted
goods separately in its books of account.
- Whether the petitioner’s explanation that it had no knowledge of
the GST Portal-uploaded order and that its accountant had not informed it
justified another opportunity.
- Whether equitable relief should be conditioned upon deposit of 25%
of the disputed tax amount.
- Whether any bank account attachment made pursuant to the impugned
assessment should continue after the assessment order was set aside.
Petitioner’s
Arguments
The petitioner advanced separate explanations for
each discrepancy.
1. GSTR-3B
vs GSTR-2A Input Mismatch
The petitioner contended that:
There is no excess claim of ITC under Section 16 of
the Act.
The petitioner stated that it was ready to:
- file a detailed reply;
- submit connected records; and
- comply with the requirements contemplated under Circular No.
183/15/2022 dated 27.12.2022.
The petitioner further contended that once the
requirements of the circular were complied with, there would be no liability
under the GST Act.
Thus, the petitioner’s case was that the mismatch
required proper reconciliation and verification of supporting documents rather
than continuation of an ex parte determination.
2. ITC
Reversal on Non-Business Transactions and Exempted Goods
The petitioner contended that:
- ITC had been claimed only on related business goods;
- ITC had not been claimed on exempted goods;
- taxable goods and exempted goods were separately maintained in
the books of account; and
- therefore, according to the petitioner, the question of reversal of
ITC did not arise.
This explanation is expressly recorded in the
second row of the page 3 table.
3. Reason
for Non-Participation
The petitioner explained that:
- the impugned order had been uploaded on the GST Portal without its
knowledge; and
- the accountant had not informed the petitioner about the impugned
order.
The same reason was recorded in relation to the
second discrepancy by use of “do”/ditto in the judgment table.
The petitioner therefore sought another opportunity
to place its reply and documentary records before the assessing authority.
Respondent’s
Arguments
The respondent was represented by the learned
Government Standing Counsel.
The judgment records that the High Court heard:
- learned counsel for the petitioner; and
- learned Government Standing Counsel for the respondent.
However, the six-page order does not separately
reproduce any detailed independent counter-submissions made by the
respondent concerning:
- the alleged GSTR-3B vs GSTR-2A mismatch;
- the petitioner’s assertion that there was no excess ITC;
- the applicability or satisfaction of Circular No. 183/15/2022;
- the alleged non-business transactions;
- exempted goods;
- separate maintenance of taxable and exempted goods in the books of
account; or
- the petitioner’s explanation concerning the accountant.
Therefore, to preserve the meaning of the judicial
record, no additional departmental argument should be attributed to the
respondent beyond what is expressly recorded.
Court Order
/ Findings
The Madras High Court considered:
- the nature of the discrepancies;
- the explanation provided by the assessee; and
- the reason given before the Court for not availing the earlier
opportunity.
The Court held that an opportunity could be granted
to the assessee to:
- present its submissions; and
- produce relevant supporting documents before the respondent
assessing officer.
The Court observed that it had been extending such
opportunities on equitable grounds, though under appropriate conditions.
Accordingly, the Court granted a fresh opportunity
subject to the condition that the petitioner deposit 25% of the disputed tax
amount.
The writ petition was allowed on the following
terms:
- within four weeks from receipt of a web copy of the order,
the petitioner shall deposit 25% of the disputed tax amount with
the respondent;
- the petitioner need not wait for a certified copy of the order;
- upon such deposit, the impugned order dated 17.12.2025 shall
stand set aside;
- the matter shall stand remanded back to the respondent;
- the assessee shall appear before the respondent without fail;
- the assessee shall submit its reply and documents in support of its
claim;
- the respondent shall reconsider the matter afresh and pass orders
in accordance with law;
- because the impugned assessment order is set aside, any
attachment of the bank account made pursuant to the impugned order shall
stand raised;
- no costs were awarded; and
- the connected miscellaneous petition was closed.
The conditional deposit and remand directions are
set out on page 4, while closure of the proceedings is completed on page
5 of the judgment.
Important
Clarification
This judgment does not finally hold that the
petitioner had no excess ITC claim.
It also does not conclusively determine
that:
- every GSTR-3B vs GSTR-2A mismatch is legally irrelevant;
- Circular No. 183/15/2022 automatically extinguishes GST liability;
- the petitioner has already complied with all requirements of the
circular;
- ITC was actually claimed only on business-related goods;
- no ITC was claimed on exempted goods;
- the petitioner had conclusively maintained taxable and exempted
goods separately in its books;
- no proportionate ITC reversal was legally required; or
- the impugned demand was incorrect on merits.
Those statements form part of the assessee’s
explanation on merits, as recorded in the judgment.
The High Court did not finally adjudicate those
factual and legal contentions. Instead, it:
- granted a fresh opportunity;
- permitted filing of replies and supporting documents;
- directed reconsideration by the assessing authority; and
- imposed a 25% disputed-tax deposit condition.
Therefore, this ruling is a conditional remand for
fresh adjudication, not a final declaration of ITC eligibility.
A further important clarification is that the Court
did not expressly hold that non-information by an accountant automatically
invalidates a GST assessment. The explanation was considered together with:
- the nature of the discrepancies;
- the assessee’s proposed merits defence; and
- the equitable basis for granting another opportunity.
Sections
Involved
Section 73 of the TNGST Act, 2017:
The impugned assessment order dated 17.12.2025 was expressly passed under this
provision.
Section 16 of the GST Act – Input Tax Credit:
The petitioner expressly contended that there was no excess claim of ITC under
Section 16.
Article 226 of the Constitution of India:
The writ petition was filed under this provision seeking a Writ of
Certiorarified Mandamus.
Circular No. 183/15/2022 dated 27.12.2022:
The petitioner relied upon this circular in relation to the GSTR-3B vs GSTR-2A
mismatch and stated that it was prepared to submit connected records in
accordance with it.
Important
Provision Clarification on ITC Reversal
The judgment describes the discrepancy as:
“ITC to be reversed on non-business transactions
and exempted goods.”
However, the six-page order does not expressly
identify a separate statutory section number for this reversal issue.
Therefore, although broader GST law may involve
provisions governing business/non-business use and exempt supplies, no
unmentioned provision should be presented as having been expressly cited or
adjudicated in this judgment.
Link to download the order -
https://mytaxexpert.co.in/uploads/1783061408_366compressed.pdf
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