Madrasdated High Court · 2025

Kelambakkam, Chennai-603 103.5.HDFC Bank Limited,First Floor, No.4-217A,Jeeva Tower, OMR Road,Siruseri, Kanchipuram 603 103 .. Respondents inW.P.46862/2025W.P. No.46871 of 2025Sudha Security Protection Force Pvt.Ltd.,represented by its Managing Director,Mr. Muniasamy Mani,No.3/53, Mettu Street, IT Highway,Rajiv Ghandhi Road, Kazhipattur,Chennai, Tamil Nadu 603 103. ... Petitioner Vs.1. The Commercial Tax Officer, Thirukazhukundram Assessment Circle, Station No.42 – Wahab Nagar, Thirukazhukundram 603 109.2. The Assistant Commissioner (ST),Thirukazhukundarm Assessment Circle,Station No.42 – Wahab Nagar,Thirukazhukundram 603 109.3. The Deputy Commissioner (ST),No.26, Abhirami Complex,Kanchipuram High Road, Thimmavaram,Chengalpattu 603 101.4. HDFC Bank Limited,First Floor, No.4-217A,Jeeva Tower, OMR Road,Siruseri, Kanchipuram 603 103.... Respondents W.P.No. 46862 of 2025 Sudha Security Protection Force Pvt.Ltd.,represented by its Managing Director,Mr. Muniasamy Mani,2/14 https://www.mhc.tn.gov.in/judis No.3/53, Mettu Street, IT Highway,Rajiv Ghandhi Road, Kazhipattur,Chennai, Tamil Nadu 603 103. ... Petitioner in W.P.46856/2025 Vs.1. The Assistant Commissioner (ST), Thirukazhukundarm Assessment Circle, Station No.42 – Wahab Nagar, Thirukazhukundram 603 109.2. The Deputy Commissioner (ST), No.26, Abhirami Complex, Kanchipuram High Road, Thimmavaram,Chengalpattu 603 101.3. IDBI Bank, Sholinganallur Branch, Vishnu Illam, 1/12, Rajiv Gandhi Salai, Old Mahabalipuram Road, Chemmancheri, Chennai 600 119. … RespondentsW.P.No. 46865 of 2025Sudha Security Protection Force Pvt.Ltd.,represented by its Managing Director,Mr. Muniasamy Mani,No.3/53, Mettu Street, IT Highway,Rajiv Ghandhi Road, Kazhipattur,Chennai, Tamil Nadu 603 103. ... Petitioner Vs.1. The Assistant Commissioner (ST), Thirukazhukundarm Assessment Circle, Station No.42 – Wahab Nagar, Thirukazhukundram 603 109.2. The Deputy Commissioner (ST), No.26, Abhirami Complex, Kanchipuram High Road, 3/14 https://www.mhc.tn.gov.in/judis Thimmavaram, Chengalpattu 603 101.3. IDBI Bank, Sholinganallur Branch, Vishnu Illam, 1/12, Rajiv Gandhi Salai, Old Mahabalipuram Road, Chemmancheri, Chennai 600 119. 4. HDFC Bank Limited, First Floor, No.4-217A, Jeeva Tower, OMR Road, Siruseri, Kanchipuram 603 103... RespondentsW.P.No.46882 of 2025Sudha Security Protection Force Pvt.Ltd.,represented by its Managing Director,Mr. Muniasamy Mani,No.3/53, Mettu Street, IT Highway,Rajiv Ghandhi Road, Kazhipattur,Chennai, Tamil Nadu 603 103. ... Petitioner Vs.1. The Assistant Commissioner (ST), Thirukazhukundarm Assessment Circle, Station No.42 – Wahab Nagar, Thirukazhukundram 603 109.2. The Deputy Commissioner (ST), No.26, Abhirami Complex, Kanchipuram High Road, Thimmavaram,Chengalpattu 603 101.3. IDBI Bank, Sholinganallur Branch, Vishnu Illam, 1/12, Rajiv Gandhi Salai, Old Mahabalipuram Road, Chemmancheri, Chennai 600 119. … Respondents4/14 https://www.mhc.tn.gov.in/judis W.P.No. 46894 of 2025Sudha Security Protection Force Pvt.Ltd.,represented by its Managing Director,Mr. Muniasamy Mani,No.3/53, Mettu Street, IT Highway,Rajiv Ghandhi Road, Kazhipattur,Chennai, Tamil Nadu 603 103. ... Petitioner Vs.1. The Assistant Commissioner (ST), Thirukazhukundarm Assessment Circle, Station No.42 – Wahab Nagar, Thirukazhukundram 603 109.2. The Deputy Commissioner (ST), No.26, Abhirami Complex, Kanchipuram High Road, Thimmavaram,Chengalpattu 603 101.3. IDBI Bank, Sholinganallur Branch, Vishnu Illam, 1/12, Rajiv Gandhi Salai, Old Mahabalipuram Road, Chemmancheri, Chennai 600 119. … RespondentsW.P.No. 46888 of 2025Sudha Security Protection Force Pvt.Ltd.,represented by its Managing Director,Mr. Muniasamy Mani, No.3/53, Mettu Street, IT Highway,Rajiv Ghandhi Road, Kazhipattur,Chennai, Tamil Nadu 603 103. ... Petitioner Vs.1. The Assistant Commissioner (ST), Thirukazhukundarm Assessment Circle, Station No.42 – Wahab Nagar, Thirukazhukundram 603 109.5/14 https://www.mhc.tn.gov.in/judis

2. The Deputy Commissioner (ST), No.26, Abhirami Complex, Kanchipuram High Road, Thimmavaram, Chengalpattu 603 101.3. The Karur Vysya Bank Limited, Plot No.12, Malayappa Mudali Street, Kelambakkam, Chennai-603 103. … RespondentsW.P.No.46938 of 2025Sudha Security Protection Force Pvt.Ltd.,represented by its Managing Director,Mr. Muniasamy Mani,No.3/53, Mettu Street, IT Highway,Rajiv Ghandhi Road, Kazhipattur,Chennai, Tamil Nadu 603 103. ... Petitioner Vs.1. The Assistant Commissioner (ST),Thirukazhukundarm Assessment Circle,Station No.42 – Wahab Nagar,Thirukazhukundram 603 109.2. The Deputy Commissioner (ST),No.26, Abhirami Complex,Kanchipuram High Road, Thimmavaram,Chengalpattu 603 101.3. HDFC Bank Limited,First Floor, No.4-217A,Jeeva Tower, OMR Road,Siruseri, Kanchipuram 603 103. .. RespondentsPrayer in W.P.No.46856 of 2025 : Writ Petition filed under Art.226 of the Constitution of India praying to call for the records relating to the impugned order in Original No.GSTIN 33AARCS3961J1ZV/2018-19, dated 13.01.2023 in Form DRC-07 bearing Reference No.ZD3301230540509 passed by the 1st respondent and to quash the 6/14 https://www.mhc.tn.gov.in/judis same.Prayer in 46871 of 2025: Writ Petition filed under Art.226 of the Constitution of India praying for issuance of Writ of Certiorari to call for the records relating to the impugned order in Original bearing ReferenceNo.ZD331224115286R, dated 13.12.2024 in Form GST DRC-07 bearing Reference No.33AARCS3961J1ZV/2017-18 passed by the 1st respondent and to quash the same.Prayer in W.P.No. 46862 of 2025 : Writ Petition filed under Art.226 of the Constitution of India praying for issuance of Writ of Certiorari to call for the records relating to the impugned order in Original No.GSTIN 33AARCS3961J1ZV/2019-20, dated 13.01.2023 in Form GST DRC-07 bearing Reference No.ZD330123054078R passed by the 1st respondent and consequent bank attachment notice issued by the 1st Respondent and to quash the same.Prayer in W.P.No. 46865 of 2025: Writ Petition filed under Art.226 of the Constitution of India praying for issuance of Writ of Certiorari to call for the records relating to the impugned order in Original No.GSTIN33AARCS3961J1ZV/2020-21 dated 13.01.2023 in Form GST DRC-07 bearing Reference No.ZD3301230541242 passed by the 1st respondent and to quash the same.Prayer in W.P.No.46882 of 2025: Writ Petition filed under Art.226 of the Constitution of India praying for issuance of Writ of Certiorari to call for the records relating to the impugned order in Original No.GSTIN 33AARCS3961J1ZV/2017-18 dated 03.01.2023 in Form GST DRC-07 bearing Reference No.ZD3301230079391 passed by the 1st respondent and to quash the same.7/14 https://www.mhc.tn.gov.in/judis Prayer in W.P.No. 46894 of 2025 : Writ Petition filed under Art.226 of the Constitution of India praying for issuance of Writ of Certiorarified Mandamus to call for the records relating to the impugned Bank Attachment Notice bearing Reference No.GSTIN 33AARCS3961J1ZV/2017-18 to 2021-21 dated 04.09.2023, issued to the 3rd respondent by the 1st respondent and to quash the same and direct the 1st respondent to lift the attachment placed on the Petitioners Bank Account Number 0887102000002097Prayer in W.P.No. 46888 of 2025: Writ Petition filed under Art.226 of the Constitution of India praying for issuance of Writ of Certiorarified Mandamus to call for the records relating to the impugned Bank Attachment Notice bearing Reference No.GSTIN 33AARCS3961J1ZV/2017-18, dated 27.06.2025 issued to the 3rd respondent by the 2nd respondent and to quash the same and direct the 2nd respondent to lift the attachment placed on the Petitioners Bank Account Number 1293155000155274.Prayer in W.P.No.46938 of 2025: Writ Petition filed under Art.226 of the Constitution of India praying to call for the records relating to the impugned order in Original No.GSTIN33AARCS3961J1ZV/2017-18 to 2020-21, dated 03.07.2025, issued to the 3rd Respondent by the 2nd Respondent and to quash the same and direct the 2nd respondent to lift the attachment placed on the petitioners Bank Account Number 50100338235688. For Petitioner (in all W.Ps) : M/s.Manasa. S for Mr.Lawrence A.For Respondents in WP.46856/2025: Ms.P.Selvi, for R1 & R2 Govt.Advocate8/14 https://www.mhc.tn.gov.in/judis Mr.C.Mohan, M/s.A.Rexy Josephine Mary for M/s.King & Patridge for R5For Respondents in WP.46938/2025: Ms.P.Selvi, for R1 & R2 Govt.Advocate Mr.C.Mohan, M/s.A.Rexy Josephine Mary for M/s.King & Patridge for R3 For Respondents in WP.46888/2025: Ms.P.Selvi, for R1 & R2 Govt.AdvocateFor Respondents in WP.46882/2025: Ms.P.Selvi, for R1 & R2 Govt.Advocate For Respondents in WP.46865/2025: Ms.P.Selvi, for R1 & R2 Govt.Advocate Mr.C.Mohan, M/s.A.Rexy Josephine Mary for M/s.King & Patridge for R4For Respondents in WP.46862/2025: Ms.P.Selvi, GA for R1 & R2For Respondents in WP.46871/2025: Ms.P.Selvi, for R1 to R3 Govt.Advocate Mr.C.Mohan, M/s.A.Rexy Josephine Mary for M/s.King & Patridge for R4 Respondents in WP.46894/2025 : Ms.P.Selvi, for R1 & R2 Govt.AdvocateCOMMON ORDER By this common order, all the eight Writ Petitions are disposed of. In the following Writ petitions, the Petitioner has challenged the computation of interest under Section 50 of the respective GST Enactment Act.9/14 https://www.mhc.tn.gov.in/judis

2. Learned counsel for the Petitioner submits that the Petitioner on 20.02.2024 has already paid a sum of Rs.31,39,125/- out of the aforesaid sum of Rs.44,39,325/-. He further submits that the above computation has been made for the first time in the respective impugned Orders. According to the learned counsel for the Petitioner, the amount to be paid towards interest is only Rs.31,39,125/- and not Rs.44,39,325/- and that the computation is incorrect. 3. Learned counsel for the Respondents fairly concedes that the above amount as mentioned above appears to have been paid by the Petitioner.10/14 https://www.mhc.tn.gov.in/judis

4. Recording the above submission of the learned counsel for the Respondents, the above mentioned Writ Petitions are disposed by giving an opportunity to the Petitioner to explain the amount payable by the Petitioner towards interest is not over and above Rs.31,39,125/- which was purportedly paid on 20.02.2024. 5. With a view to secure the interest of Revenue, Petitioner is however directed to deposit another Rs.2.5 lakhs over and above the amounts already deposited within a period of 30 days from the date of receipt of a copy of this order. 6. Insofar as the rest of the writ Petitions are concerned as challenge is to the recovery notices issued to the Petitioner’s bank detailed above.7. In view of the order s passed in so far as the computation of the interest in Writ Petition, the impugned recovery proceedings are directed to be kept in abeyance. Pending further orders by the Respondent. Consequently, all attachment of the Petitioner’s bank account shall stand lifted subject to Petitioner depositing Rs.2.5 lakhs as ordered above.11/14 https://www.mhc.tn.gov.in/judis

8. The respondents shall thereafter proceed to pass an appropriate order in so far as the interest is concerned within a period of three months from the date of receipt of a copy of this order . 9. These Writ Petitions stands disposed of with the above observations. No costs. Connected Writ Miscellaneous Petitions are closed. 01.12.2025Neutral Citation : Yes/Nogv12/14 https://www.mhc.tn.gov.in/judis To:1.The Assistant Commissioner (ST),Thirukazhukundarm Assessment Circle,Station No.42 – Wahab Nagar,Thirukazhukundram 603 109.2. The Deputy Commissioner (ST),No.26, Abhirami Complex,Kanchipuram High Road, Thimmavaram,Chengalpattu 603 101.3.IDBI Bank,Sholinganallur Branch, Vishnu Illam,1/12, Rajiv Gandhi Salai, Old Mahabalipuram Road,Chemmancheri, Chennai 600 119.4. The Karur Vysya Bank Limited, Plot No.12, Malayappa Mudali Street,Kelambakkam, Chennai-603 103.5. HDFC Bank Limited,First Floor, No.4-217A,Jeeva Tower, OMR Road,Siruseri, Kanchipuram 603 103.13/14 https://www.mhc.tn.gov.in/judis C.SARAVANAN, J.gvW.P.Nos.46856, 46871, 46862, 46865, 46882, 46894, 46888 & 46938, of 2025 &WMP.Nos.52324, 52328,52431,52433, 52371,52372,52377,52376, 52361, 52363, 52340, 52341, 52334,52335, 52349 &52353 of 202501.12.202514/14