M/S.Mano Logistics v. The State Tax Officer
IN THE HIGH COURT OF JUDICATURE AT MADRAS
DATED : 09.01.2026 CORAM :
THE HONOURABLE MR.JUSTICE C.SARAVANAN and W.M.P.Nos.666, 667, 669, 674, 676, 678, 680, 687, 691, 682, 684, 686, 696, 699, 703, 702, 704, 705, 712, 713 and 715 of 2026 M/s. Mano Logistics, represented by its Managing Partner, Mr.J.Saravana Bavan, No.204, 2nd Floor, Arangasamy Nagar, Civil Aerodrome Post, Coimbatore - 641 014.
... Petitioner in all WPs Vs.
1. The State Tax Officer Roving Squad - 4, Coimbatore.
2. The Assistant Commissioner (ST) Peelamedu (South) Circle, Coimbatore.
3. The Bank Manager, Kotak Mahindra Bank Limited Ground Floor, Bathija Blossoms Site No.34, Door No.229 & 29/1, Mettupalayam, Thandagam Extension Road, Block No.14, East, Thiruvenkataswamy Road, R.S.Puram, Coimbatore - 641 002.
... Respondents in all WPs Page No. 1 of 8
Prayer in W.P.No.560 of 2026 : Writ Petition filed under Article 226 of the Constitution of India, for issuance of a Writ of Certiorari, calling for the records relating to the impugned proceedings of the first respondent in GSTIN:33ABAFM4475A2ZP/2018-19 dated 10.06.2025, the connected order under Section 74 of the CGST/TNGST Act, 2017, also dated 10.06.2025, together with the summary of the order in form GST -07 bearing Reference No.ZD330625088834Z dated 10.06.2025 and to quash all the impugned proceedings as passed contrary to the provisions of the CGST/TNGST Act, 2017, and against the principles of natural justice. Prayer in W.P.No.
569 of 2026: Writ Petition filed under Article 226 of the Constitution of India, for issuance of a Writ of Certiorari, calling for the records relating to the impugned proceedings of the first respondent in GSTIN:33ABAFM4475A2ZP/2021-22 dated 17.06.2025, the connected order under Section 74 of the CGST/TNGST Act, 2017, also dated 17.06.2025, together with the summary of the order in form GST -07 bearing Reference No.ZD330625165371H dated 17.06.2025 and to quash all the impugned proceedings as passed contrary to the provisions of the CGST/TNGST Act, 2017, and against the principles of natural justice. Prayer in W.P.No.
574 of 2026: Writ Petition filed under Article 226 of the Constitution of India, for issuance of a Writ of Certiorari, calling for the records relating to the impugned proceedings of the first respondent in GSTIN:33ABAFM4475A2ZP/2020-21 dated 17.06.2025, the connected order under Section 74 of the CGST/TNGST Act, 2017, also dated 17.06.2025, together with the summary of the order in form GST -07 bearing Reference Page No.
No.ZD3306251635947 dated 17.06.2025 and to quash all the impugned proceedings as passed contrary to the provisions of the CGST/TNGST Act, 2017, and against the principles of natural justice. Prayer in W.P.No.576 of 2026: Writ Petition filed under Article 226 of the Constitution of India, for issuance of a Writ of Certiorari, calling for the records relating to the impugned proceedings of the respondent in GSTIN:33ABAFM4475A2ZP/2019-20 dated 17.06.2025, the connected order under Section 74 of the CGST/TNGST Act, 2017, also dated 17.06.2025, together with the summary of the order in form GST -07 bearing Reference No.ZD330625161127I dated 17.06.2025 and to quash all the impugned proceedings as passed contrary to the provisions of the CGST/TNGST Act, 2017, and against the principles of natural justice. Prayer in W.P.No.
583 of 2026: Writ Petition filed under Article 226 of the Constitution of India, for issuance of a Writ of Certiorari, calling for the records relating to the impugned proceedings of the first respondent in GSTIN:33ABAFM4475A2ZP/2022-23 dated 17.06.2025, the connected order under Section 74 of the CGST/TNGST Act, 2017, also dated 17.06.2025, together with the summary of the order in form GST -07 bearing Reference No.ZD330625167136D dated 17.06.2025 and to quash all the impugned proceedings as passed contrary to the provisions of the CGST/TNGST Act, 2017, and against the principles of natural justice. Prayer in W.P.No.588 of 2026: Writ Petition filed under Article 226 of the Constitution of India, for issuance of a Writ of Certiorari, calling for the records relating to the impugned proceedings of the first respondent in Page No.
GSTIN:33ABAFM4475A2ZP/2023-24 dated 17.06.2025, the connected order under Section 74 of the CGST/TNGST Act, 2017, also dated 17.06.2025, together with the summary of the order in form GST -07 bearing Reference No.ZD3306251691569 dated 17.06.2025 and to quash all the impugned proceedings as passed contrary to the provisions of the CGST/TNGST Act, 2017, and against the principles of natural justice. Prayer in W.P.No.593 of 2026: Writ Petition filed under Article 226 of the Constitution of India, for issuance of a Writ of Certiorari, calling for the records relating to the impugned proceedings of the first respondent in GSTIN:33ABAFM4475A2ZP/2024-25 dated 17.06.2025, the connected order under Section 74 of the CGST/TNGST Act, 2017, also dated 17.06.2025, together with the summary of the order in form GST -07 bearing Reference No.
ZD330625171796Z dated 17.06.2025 and to quash all the impugned proceedings as passed contrary to the provisions of the CGST/TNGST Act, 2017, and against the principles of natural justice. For Petitioner : M/s.Benuel Ritesh Rajkumar for Mr.P.Rajkumar in all WPs For R1 & R2 : Mr.C.Harsharaj Special Government Pleader in all WPs COMMON ORDER Mr.C.Harsharaj, learned Special Government Pleader, takes notice for the Respondents 1 & 2.
Page No. 4 of 8
2. This Writ Petition is being disposed of at the time of admission with the consent of the learned counsel for the Petitioner and learned Special Government Pleader for the Respondents 1 & 2.
3. By this common order, all the seven writ petitions are disposed of.
4. In these writ petitions, the petitioner has challenged the impugned orders as tabulated below:- Sl.
No.
Writ Petition Number Assessment Year Date of Show Cause Notice Date of Impugned Assessment orders 1.
W.P.No.560 / 2026 2018-2019 03.02.2025 10.06.2025 2.
W.P.No.576 / 2026 2019-2020 03.02.2025 17.06.2025 3.
W.P.No.574 / 2026 2020-2021 03.02.2025 17.06.2025 4.
W.P.no.569 / 2026 2021-2022 03.02.2025 17.06.2025 5.
W.P.no.583 / 2026 2022-2023 03.02.2025 17.06.2025 6.
W.P.No.588 / 2026 2023-2024 03.02.2025 17.06.2025 7.
W.P.No.593 / 2026 2024-2025 03.02.2025 17.06.2025
5. The aforesaid impugned Assessment orders were preceded by respective Show Cause Notices in Form GST DRC-01, all dated 03.02.2025. The petitioner also filed replies all dated 30.01.2025 to the said Show Cause Notices. Although the replies were partly considered, the demands were nevertheless confirmed.
Page No. 5 of 8
6. The petitioner was also issued with an intimation in Form GST DRC-01A all dated 25.01.2025 for the respective Assessment Years, which are covered by the impugned orders dated 10.06.2025 and 17.06.2025. The period of limitation for filing an appeal against the impugned Assessment orders have already expired.
7. The learned counsel for the petitioner submits that liberty may be granted to the petitioner to file appeals against the impugned orders.
8. It is noticed that almost 50% of the disputed tax has already been recovered from the petitioner's Electronic Credit Leger towards the tax liability. Ordinarily, the petitioner would have been required to deposit only 10% of the disputed tax if the appeals had been filed within the prescribed time.
9. Following the consistent view taken under similar circumstances, the writ petitions are disposed of by granting liberty to the petitioner to file a statutory appeal before the Appellate Authority, subject to the petitioner depositing 25% of the disputed tax in cash from the Petitioner's Electronic Cash Register within a period of 30 days from the date of receipt of a copy of this order.
Page No. 6 of 8
10. However, since 50% of the amount has already been recovered from the petitioner, no further amount shall be required to be deposited for the purpose of redoing the proceedings.
11. Accordingly, the petitioner shall file a statutory appeal against the respective impugned orders within a period of thirty (30) days from the date of receipt of a copy of this order. In the event the appeals are filed within the time prescribed, the Appellate Authority shall take up the appeals and dispose of the same on merits, without reference to limitation.
12. Needless to state, before passing any final orders the Appellate Authority shall give due notice to the petitioner.
13. This Writ Petitions stand disposed of with the above observations. No costs. Connected Writ Miscellaneous Petitions are closed. 09.01.2026 av Page No. 7 of 8
C.SARAVANAN, J.
av To
1. The State Tax Officer Roving Squad - 4, Coimbatore.
2. The Assistant Commissioner (ST) Peelamedu (South) Circle, Coimbatore.
3. The Bank Manager, Kotak Mahindra Bank Limited Ground Floor, Bathija Blossoms Site No.34, Door No.229 & 29/1, Mettupalayam, Thandagam Extension Road, Block No.14, East, Thiruvenkataswamy Road, R.S.Puram, Coimbatore - 641 002.
W.P.Nos.560,569,574, 576, 583, 588 & 593 of 2026 and W.M.P.Nos.666, 667, 669, 674, 676, 678, 680, 687, 691, 682, 684, 686, 696, 699, 703, 702, 704, 705, 712, 713 and 715 of 2026 09.01.2026 Page No. 8 of 8