Sadaiyan Karunanidhi v. Commercial Tax Officer

IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED : 24.03.2026 CORAM :

THE HONOURABLE MR.JUSTICE C.SARAVANAN

11402, 11406, 11411, 11427 & 11434 of 2026

and W.M.P.Nos.12406, 12408, 12411, 12416, 12445, 12458, 12451, 12452, 12421 and 12423 of 2026 Sadaiyan Karunanidhi 173, Devariampakkam Kanchipuram Kancheepuram Tamil Nadu 603 110.

... Petitioner in all WPs

Vs. Commercial Tax Officer Thirukazhukundram Chengalpattu, Tamil Nadu. ... Respondent in all WPs Prayer

in W.P.No.11402 of 2026

: Writ Petition filed under Article 226 of the Constitution of India, for issuance of a Writ of Certiorari, calling for the records of the impugned Show Cause Notice issued by the Respondent GSTIN. 33DFMPK6183J1Z0 /2021-22 dated 23.01.2026 for the Assessment year 2021-22 and quash the same.

Page No. 1 of 6

Prayer in W.P.No.11406 of 2026: Writ Petition filed under Article 226 of the Constitution of India, for issuance of a Writ of Certiorari, calling for the records of the impugned Show Cause Notice issued by the Respondent GSTIN. 33DFMPK6183J1Z0 /2022-23 dated 07.08.2025 for the Assessment year 2022-23 and quash the same. Prayer in W.P.No.11411 of 2026: Writ Petition filed under Article 226 of the Constitution of India, for issuance of a Writ of Certiorari, calling for the records of the impugned Show Cause Notice issued by the Respondent GSTIN. 33DFMPK6183J1Z0 /2021-22 dated 18.09.2025 for the Assessment year 2021-22 and quash the same. Prayer in W.P.No.11427 of 2026: Writ Petition filed under Article 226 of the Constitution of India, for issuance of a Writ of Certiorari, calling for the records of the impugned Show Cause Notice issued by the Respondent GSTIN. 33DFMPK6183J1Z0 /2022-23 dated 17.09.2025 for the Assessment year 2022-23 and quash the same. Prayer in W.P.No.11434 of 2026: Writ Petition filed under Article 226 of the Constitution of India, for issuance of a Writ of Certiorari, calling for the records of the impugned Show Cause Notice issued by the Respondent GSTIN. 33DFMPK6183J1Z0 /2022-23 dated 18.09.2025 for the Assessment year 2022-23 and quash the same. Page No. 2 of 6

For Petitioner : Mr. Rukmani Venugopalan in all WPs For Respondent : Mrs.K.Vasanthamala in all WPs Government Advocate COMMON ORDER Mrs.K.Vasanthamala, learned Government Advocate takes notice for the Respondent.

¶2This Writ Petition is being disposed of at the stage of admission itself with the consent of the learned counsel for the Petitioner and the learned Government Advocate for the Respondent.

3.In these writ petitions, the petitioner has challenged the respective Show Cause Notices, as detailed below: S.No Writ Petition Nos. Impugned DRCs

¶1W.P.No.11402 of 2026 DRC 01 dated 23.01.2026

¶2W.P.No.11411 of 2026 DRC 01 dated 18.09.2025

¶3W.P.No.11406 of 2026 DRC 01 dated 07.08.2025 Page No. 3 of 6

¶4W.P.No.11427 of 2026 DRC 01 dated 17.09.2025

¶5W.P.No.11434 of 2026 DRC 01 dated 18.09.2025

4.It is submitted by the learned counsel for the Petitioner that multiple Show Cause Notices have been issued for the relevant tax periods, and were issued through five separate notices without any overlap. He further submitted that the Petitioner is willing to deposit 10% of the seigniorage fees as per the usual orders that have been passed under similar circumstances. However, the consolidated notice is to be issued, as there is a duplication of the demand.

5.The learned counsel for the Respondent submitted that there is apparent duplication of the demand in the respective Show Cause Notice and submitted that a consolidated notice will be issued for the relevant tax periods, allowing the Petitioner to comply with the other stipulations.

6.Recording the same, these writ petitions stand disposed of by directing the Respondent to issue consolidated Show Cause Notices for the respective tax periods. On receipt of the same, the Petitioner shall deposit 10% of the seigniorage fee with the Tamil Nadu District Mineral Foundation Trust and Page No. 4 of 6

await the orders of the Hon'ble Supreme Court. The Petitioner shall be bound by the orders of the Hon'ble Supreme Court, and the amount paid shall be subject to future appropriation or adjustment pursuant to the orders of Hon'ble Supreme Court.

7.These writ petitions are disposed of with the above directions. Consequently, connected miscellaneous petitions are closed. No Costs.

24.03.2026 Index: Yes/No Speaking/Non-speaking order ssr Page No. 5 of 6

C.SARAVANAN, J. ssr To Commercial Tax Officer Thirukazhukundram Chengalpattu, Tamil Nadu.

11402, 11406, 11411, 11427 & 11434 of 2026

and W.M.P.Nos.12406, 12408, 12411, 12416, 12445, 12458, 12451, 12452, 12421 and 12423 of 2026

24.03.2026 Page No. 6 of 6