Over 200 Pages of Supporting Documents Ignored: Madras HC sends back GST Demand for Proper Adjudication [Read Order]

Following an inspection at the M/s. Chakra Chains Jewellery (P) Ltd’s premises on 11 and 12 July 2024, during which a sworn statement was recorded from its Director.

The petitioner filed an initial reply on 15 July 2024. Subsequently, the State Tax Officer issued a notice in Form DRC-01 on 9 January 2025, to which a detailed reply, along with voluminous 200 pages documentary evidence, was submitted on 8 April 2025.

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The adjudicating authority, despite acknowledging receipt of these materials in the impugned order, concluded that the petitioner had merely reiterated earlier submissions and had failed to avail the opportunity to respond at the inspection stage. The order dismissed the taxpayer’s reliance on the documents and upheld the initial statement recorded during inspection.

Justice C. Saravanan observed that such reasoning reflected “a total non-application of mind.” The Court held that the authority was obligated to independently assess all records, including the statements, initial reply, and subsequent detailed reply, to determine whether the demand should be sustained or dropped.

Accordingly, the Court set aside the order issued under Section 73 of the TNGST Act, 2017, and remitted the matter for fresh adjudication on merits. The officer has been directed to pass a reasoned order after granting the petitioner a personal hearing. Accordingly, the writ petition was disposed of.

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