The Court directed the assessing officer to examine whether turnover brought to tax in the Tirunelveli unit had also been taxed in Coimbatore, observing that records should be looked at holistically.
The Madras High Court has held that where the same turnover is alleged to have been brought to tax in respect of two separate units of the same assessee, it constitutes a rectifiable mistake that ought to be examined under Section 161 of the Tamil Nadu GST Act, and the assessing officer cannot reject the rectification petition as an impermissible review [M/s. Ferrosco Industries Pvt. Ltd. v. The Deputy Commissioner (GST Appeal)].
The bench of Justices Dr. Anita Sumanth and K. Rajasekar was hearing a writ appeal by an assessee which had two registered units — a factory in Tirunelveli and a registered office in Coimbatore. The appellant contended that the Coimbatore assessment included turnover that had already been assessed and was subject to a pending appeal at the Tirunelveli unit.
The assessing authority had rejected the rectification petition, holding that the relief sought amounted to a review impermissible under the Act. The High Court disagreed, holding that "the records of the assessee should be looked at holistically in order to ensure that turnover suffers tax only at one point." The Court set aside the rectification rejection order on the double taxation aspect and directed a personal hearing on 22.10.2026 for reworking the turnover.
2026-juristway.com-3074-HC(Madras)-GST
