Madras High Court Directs Consolidated GST Adjudication After Trader Receives Two Assessments For Same Year

After a Chennai-based trader received two separate GST assessment orders for the same financial year, the Madras High Court remanded the matter for consolidated adjudication by a single authority.

A single-judge bench of Justice C Saravanan noted that, for the same tax period, “two officers who are the Respondents in the respective Writ Petitions filed respective impugned orders,” and proceeded to consider the grievance raised by the trader.

The dispute relates to two assessment orders issued for the 2020–21 financial year by different Deputy State Tax Officers of the same assessment circle. One order was dated February 12, 2025, while the other was dated February 24, 2025, each following separate show cause notices. The trader approached the High Court contending that the demands confirmed under the two orders overlapped, resulting in duplication of tax liability.

Recording the submissions, the court noted the trader's claim that “as far as the demand that was confirmed vide order dated 12.02.2025 is concerned, the entire tax liability including penalty has been paid for IGST and CGST and part of the SGST alone has been paid,” and that the balance would also be discharged.

The tax department, however, stated that it was unable to confirm the same and asserted that “there is no overlap” between the demands confirmed under the two orders.

Without expressing any view on the merits of the claims, the court remitted the matter to one authority, directing the Deputy State Tax Officer to “pass a consolidated order on merits” after giving the trader an opportunity to file replies to both show cause notices.

The bench directed the trader to deposit 25 percent of the disputed tax, clarified that “amount already paid by the Petitioner shall be adjusted towards pre-deposit of 25% of the disputed tax as ordered above, which will be however subject to verification by the Respondents,”

It ordered that the attachment of the trader's bank account “shall also stand automatically vacated” upon compliance. The authority was asked to complete the exercise within three months.