Gram Vikas Trust v. Additional Commissioner of Gst and Central Excise Coimbatore

Order-in-Original 2039 / 2026 2017 – 2023

28.11.2024 Orders by State Authority Sl.No. Writ Petition No. Assessment Year Date of Impugned Order 2852 / 2026 2019 – 2020

14.08.2024 2857 / 2026 2019 – 2020

24.01.2024 2862 / 2026 2020 – 2021

06.11.2024 2865 / 2026 2019 – 2020

17.08.2024 2900 / 2026 2019 – 2020

30.08.2024 2908 / 2026 2020 – 2021

16.08.2023 2913 / 2026 2020 – 2021

22.02.2025

¶5The facts on record reveal that a Show Cause Notice in DRC-01 dated 06.01.2023 was previously issued to the petitioner, which culminated in an Order dated 16.08.2023 for the tax period 2020-2021. This order is now impugned in W.P.No.2908 of 2026.

¶6The Central Authority independently investigated the matters, recorded the submissions, and issued the Show Cause Notice dated

06.02.2024 for the tax periods 2017-2023 under Section 74 of the respective GST enactments.

¶7The petitioner failed to reply to the said notice, consequently, the impugned Order-in-Original was passed. Meanwhile, the State Authority also issued parallel notices, which have now culminated in orders for the same periods, which are impugned in W.P.Nos.2852, 2857, 2862, 2865, 2900, 2908 & 2913 of 2026.

¶8The learned counsel for the petitioner would submit that the petitioner's trust was audited by its Chartered Accountant, later, the said Chartered Accountant had passed away, the petitioner became aware of the impugned order only after recovery proceedings were initiated by attaching the bank account of the managing trustee of the petitioner.

¶9It is further submitted by the learned counsel for the petitioner that the work carried on by the petitioner is exempted under the respective GST notifications and that since the petitioner failed to respond to the above mentioned notices issued by the Central and State Authorities, the present impugned orders have been passed.

¶10It is moreover submitted by the learned counsel for the petitioner that the petitioner may be given one opportunity to explain their case and that the petitioner will deposit a sum of Rs.50 Lakhs as a condition for de novo adjudication. The learned counsel has also made an endorsement in the bundle to the following effect: "WP 2039/26 WP Nos. 2852, 2857, 2862, 2865, 2900, 2908 and 2913 of 2026 as per Instructions petitioner undertake to deposit Rs.50,00,000/- (fifty lakhs)"

¶11Since the petitioner is assessed by the State Authority, the case is remitted back to the State Authority namely 1st Respondent herein (State Tax Officer / Deputy State Tax Officer) to pass a consolidated order in respect of the demand proposed and confirmed by the impugned Order-in-Original passed by the Central Authority and the respective impugned Orders passed by the State Authority within three months, subject to the petitioner filing a reply to the notices that preceded the impugned orders and depositing a sum of Rs.50 Lakhs within a period of 30 days from the date of receipt of a copy of this order.

¶12If the petitioner complies with the above stipulations within the specified time, the attachment of the petitioner's managing trustee's bank account shall be lifted.

¶13In case the petitioner fails to comply with the above stipulations, the respondent department is at liberty to proceed against the petitioner to recover the tax in accordance with law as if these writ petitions were dismissed in limine today.

¶14These writ petitions stand disposed of with the above directions. Consequently, connected miscellaneous petitions are closed. No costs.

19.02.2026 raja To

¶1The Additional Commissioner of GST & Central Excise, No.6/7, A.T.D. Street, Racecourse Coimbatore – 641018.

¶2The Manager, Bank of India, R.N.Puram Branch, 6/659 A, Trichy Road, Dharmaraj Layout, R.N.Puram, Coimbatore – 641 045.

¶3The Manager, Union Bank of India, Singanallur Branch, 349-350, Trichy Road Singanallur, Coimbatore – 641005.

¶4The Manager, Canara Bank, Thumbalam Branch, 3/186, Main Road, Thumbalam, Tamil Nadu – 621211.

¶5The State Tax Officer, Singanallur (South) Assessment Circle, Coimbatore, Commercial Taxes Department, Dr. Balasundaram Rd, ATT Colony, Gopalapuram, Pappanaickenpalayam, Coimbatore, Tamil Nadu -641018.

¶6The Deputy State Tax Officer, Singanallur (South) Assessment Circle, Coimbatore, Commercial Taxes Department, Dr. Balasundaram Rd, ATT Colony, Gopalapuram, Pappanaickenpalayam, Coimbatore, Tamil Nadu -641018.

¶7The Commercial Tax Officer, Singanallur (South) Assessment Circle, Coimbatore, Commercial Taxes Department, Dr. Balasundaram Rd, ATT Colony, Gopalapuram, Pappanaickenpalayam, Coimbatore, Tamil Nadu -641018. W.P.No.2039oofo2026 C.SARAVANAN,oJ. raja W.P.Nos.2039,o2852,o2857,o2862,o2865,o2900,o2908o&o2913oofo2026

19.02.2026

IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED : 19.02.2026 CORAM THE HONOURABLE MR.JUSTICE C.SARAVANAN W.P.Nos.2039, 2852, 2857, 2862, 2865, 2900, 2908 & 2913 of 2026 and W.M.P.Nos.2163, 2165, 3161, 3163, 3168, 3170, 3179, 3180, 3184, 3185, 3237, 3240, 3253, 3254, 3259, 3260 of 2026 W.P.No.2039 0f 2026 Gram Vikas Trust, Rep. by its Managing Trustee Mr. M. Sivakumar, GSTIN: 33AABTG1380L2ZQ, having office at, 3/177, SK Nagar, Seelanalenpatti, Salem – 636202. ... Petitioner Vs. 1. Additional Commissioner of GST & Central Excise, Coimbatore No.6/7, A.T.D. Street, Racecourse Coimbatore – 641018. 2. Bank of India, R.N.Puram Branch, Represented by its Manager, 6/659 A, Trichy Road, Dharmaraj Layout, R.N.Puram, Coimbatore – 641 045. 3. IDFC First Bank, Salem Branch Represented by its Manager, Ground Floor, Door No.2 to 8, MNJ Complex, Kalliapillai Thoppu, SKS Hospital Road, Opp. to Ponnusamy Kalyana Mandapam Fairlands Salem – 636004. 4. Union Bank of India, Singanallur Branch, Represented by its Manager, 349-350, Trichy Road Singanallur, Coimbatore – 641005. 5. Canara Bank, Thumbalam Branch, Represented by its Manager, 3/186, Main Road, Thumbalam, Tamil Nadu – 621211. 6. State Tax Officer, Singanallur (South) Assessment Circle, Coimbatore, Commercial Taxes Department, Dr. Balasundaram Rd, ATT Colony, Gopalapuram, Pappanaickenpalayam, Coimbatore, Tamil Nadu -641018. ... Respondents W.P.Nos.2852, 2857, 2865, 2900 & 2913 of 2026 Gram Vikas Trust, Rep. by its Managing Trustee Mr. M. Sivakumar, GSTIN: 33AABTG1380L2ZQ, having office at, 3/377, SK Nagar, Seelanalenpatti, Salem – 636201. ... Petitioner Vs. 1. State Tax Officer, Singanallur (South) Assessment Circle, Coimbatore, Commercial Taxes Department, Dr. Balasundaram Rd, ATT Colony, Gopalapuram, Pappanaickenpalayam, Coimbatore, Tamil Nadu -641018. 2. Commercial Tax Officer, Singanallur (South) Assessment Circle, Coimbatore, Commercial Taxes Department, Dr. Balasundaram Rd, ATT Colony, Gopalapuram, Pappanaickenpalayam, Coimbatore, Tamil Nadu -641018. 3. Bank of India, R.N.Puram Branch, Represented by its Manager, 6/659 A, Trichy Road, Dharmaraj Layout, R.N.Puram, Coimbatore – 641 045. 4. IDFC First Bank, Salem Branch Represented by its Manager, Ground Floor, Door No.2 to 8, MNJ Complex, Kalliapillai Thoppu, SKS Hospital Road, Opp. to Ponnusamy Kalyana Mandapam Fairlands Salem – 636004. 5. Union Bank of India, Singanallur Branch, Represented by its Manager, 349-350, Trichy Road Singanallur, Coimbatore – 641005. 6. Canara Bank, Thumbalam Branch, Represented by its Manager, 3/186, Main Road, Thumbalam, Tamil Nadu – 621211. ... Respondents W.P.No.2862 of 2026 Gram Vikas Trust, Rep. by its Managing Trustee Mr. M. Sivakumar, GSTIN: 33AABTG1380L2ZQ, having office at, 3/377, SK Nagar, Seelanalenpatti, Salem – 636201. ... Petitioner Vs. 1. Deputy State Tax Officer, Singanallur (South) Assessment Circle, Coimbatore, Commercial Taxes Department, Dr. Balasundaram Rd, ATT Colony, Gopalapuram, Pappanaickenpalayam, Coimbatore, Tamil Nadu -641018. 2. Commercial Tax Officer, Singanallur (South) Assessment Circle, Coimbatore, Commercial Taxes Department, Dr. Balasundaram Rd, ATT Colony, Gopalapuram, Pappanaickenpalayam, Coimbatore, Tamil Nadu -641018. 3. Bank of India, R.N.Puram Branch, Represented by its Manager, 6/659 A, Trichy Road, Dharmaraj Layout, R.N.Puram, Coimbatore – 641 045. 4. IDFC First Bank, Salem Branch Represented by its Manager, Ground Floor, Door No.2 to 8, MNJ Complex, Kalliapillai Thoppu, SKS Hospital Road, Opp. to Ponnusamy Kalyana Mandapam Fairlands Salem – 636004. 5. Union Bank of India, Singanallur Branch, Represented by its Manager, 349-350, Trichy Road Singanallur, Coimbatore – 641005. 6. Canara Bank, Thumbalam Branch, Represented by its Manager, 3/186, Main Road, Thumbalam, Tamil Nadu – 621211. ... Respondents W.P.No.2908 of 2026 Gram Vikas Trust, Rep. by its Managing Trustee Mr. M. Sivakumar, GSTIN: 33AABTG1380L2ZQ, having office at, 3/377, SK Nagar, Seelanalenpatti, Salem –