A. Venkatachalam Civil Contractor v. The Assistant Commissioner (St)

Page1 of 5 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 01-07-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP Nos. 23374, 23377, 23384, 23549, and WMP.Nos.25336, 25338, 25342, 25520, 25522, 25527 & 25529 of 2026 In all WPs. A. Venkatachalam Civil Contractor represented by its Proprietor A.Venkatachalam No.1/7 Trichy Road, Kangeyampalayam Coimbatore 641401. ..Petitioner Vs The Assistant Commissioner (ST) Palladam-2 Assessment Circle Palladam, Tiruppur. ..Respondent Prayer in W.P.No.23374 of 2026: Writ Petition is filed under Article 226 of the Constitution of India praying for issuance of Writ of Certiorari calling for the records of the respondent in his proceedings in Order No. Mines-01/052024/ 2018-19, quash the order dated 24.05.2024 passed therein. Prayer in W.P.No.23377 of 2026: Writ Petition is filed under Article 226 of the Constitution of India praying for issuance of Writ of Certiorari calling for the records of the respondent in his proceedings in Order No. Mines-02/ 052024 / 2019-20, quash the order dated 24.05.2024 passed therein. Page2 of 5 Prayer in W.P.No.23384 of 2026: Writ Petition is filed under Article 226 of the Constitution of India praying for issuance of Writ of Certiorari calling for the records of the respondent in his proceedings in Order No. Mines-03/ 052024 / 2020-21, quash the order dated 24.05.2024 passed therein. Prayer in W.P.No.23549 of 2026: Writ Petition is filed under Article 226 of the Constitution of India praying for issuance of Writ of Certiorari calling for the records

of

the

respondent

in

his

proceedings

in GSTIN:33ABPPV8474RlZB/2020-21, quash the order dated 20.03.2026 passed therein. Prayer in W.P.No.23553 of 2026: Writ Petition is filed under Article 226 of the Constitution of India praying for issuance of Writ of Certiorari calling for the records of the respondent in his proceedings in Order No. Mines_04/052024/2021-22, quash the order dated 24.05.2024 passed therein. Prayer in W.P.No.23557 of 2026: Writ Petition is filed under Article 226 of the Constitution of India praying for issuance of Writ of Certiorari calling for the records of the respondent in his proceedings in GSTIN-33ABPPV8474RlZB /2021-22, quash the order dated 20.03.2026 passed therein. Prayer in W.P.No.23559 of 2026: Writ Petition is filed under Article 226 of the Constitution of India praying for issuance of Writ of Certiorari calling for the records of the respondent in his proceedings in GSTIN-33ABPPV8474RlZB /2022-23, quash the order dated 20.03.2026 passed therein. In all WPs. For Petitioner: Mr. P. V. Sudakar For Respondent: Ms. G. Dhana Madhri Government Counsel (Tax) Page3 of 5 COMMON ORDER All these writ petitions pertain to assessment orders wherein GST was imposed on seigniorage/royalty.

¶2Ms. G. Dhana Madhri, learned Government Counsel (Tax), accepts notice on behalf of the respondent.

¶3Learned counsel for the petitioner submits that the petitioner would pay 10% of the disputed tax demand in W.P.Nos.23374, 23377 & 23559 of 2026. As regards the orders relating to assessment periods 2020 – 2021 and 2021 – 2022, he submits that two orders were issued in respect of the same period. Therefore, he submits that 10% of the tax demand under the order impugned in W.P.No.23384 of 2026 and similarly under the order impugned in W.P.No.23557 of 2026 would be paid as a condition for remand.

¶4Subject to the petitioner remitting 10% of the disputed tax demand relating to the assessment orders for assessment period 2018 – 2019, 2019 – 2020 & 2022 – 2023 and subject further to the payment of 10% of the disputed tax demand under order dated 24.05.2024 relating to assessment period 2020 – 2021 (W.P.No.23384 of 2026) and order dated 20.03.2026 pertaining to Page4 of 5 assessment period 2021 – 2022 (W.P.No.23557 of 2026) within thirty days from the date of receipt of a copy of this order, these assessment orders are set aside and the matters are remanded for re-consideration. After providing a reasonable opportunity to the petitioner, fresh orders shall be issued within three months from the date of remittance of 10% in the manner specified above. Such orders shall not be implemented pending the final decision of the Supreme Court in pending Special Leave Petition relating to this issue.

¶5The writ petitions are disposed of on the above terms. Consequently, connected miscellaneous petitions are closed. There shall be no order as to costs. 01-07-2026 Index : Yes/No KJ To The Assistant Commissioner (ST) Palladam-2 Assessment Circle Palladam, Tiruppur. Page5 of 5 SENTHILKUMAR RAMAMOORTHY J. KJ WP Nos. 23374, 23377, 23384, 23549, and WMP.Nos.25336, 25338, 25342, 25520, 25522, 25527 & 25529 of 2026 01-07-2026