WP Nos.16780 of 2020 etc. IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 02.07.2026 CORAM THE HON'BLE MR.SUSHRUT ARVIND DHARMADHIKARI, CHIEF JUSTICE AND THE HON'BLE MR.JUSTICE G.ARUL MURUGAN WP Nos.16780, 12563, 16788, 16789, 16792 of 2020 WP No.16780 of 2020 Schaeffler India limited Rep by its Director Finance and CFO Office at 20, Royakottah Road Hosur- 635109 : Petitioner Versus 1.Union of India Rep by Secretary to Government Ministry of Finance Department of Revenue North Block New Delhi- 110 001 2.The Central Board of Indirect Taxes & Customs Rep by its chairman North Block New Delhi- 110 001 3.The Goods & Service Tax Council Rep by its Chairperson 5th floor Tower- II Jeevan Bharati building Janapath Road, Cannaught Palace, New Delhi- 110 001 4.The Commissioner of GST and Central Excise (IARC and R and T section) Salem Commissionerate, Salem- 636001 Page 1 of 4 https://www.mhc.tn.gov.in/judis WP Nos.16780 of 2020 etc. 5.The Assistant Commissioner of GST & Central Excise Hosur- I Division

Thally Road, Hosur- 635 109 : Respondents Prayer: WP No.16780 of 2020 filed under Article 226 of the Constitution of India for issuance of a Writ of Declaration declaring that Section 140 of the central Goods and Service Tax Act 2017 read with Rule 117 and 120-A of the Central Goods and Service Tax Rules 2017 insofar as it prescribes time period for filing/ revision of GSt TRAN-1 for transition of Cenvat Credit Ling in balance as on 31.7.2017 as arbitrary, invidiously discriminatroy and violative of Article 14, 19(1) (g) 245 and 246A of the Constitution of India. WP No.16792 of 2020 filed under Article 226 of the Constitution of India for issuance of a Writ of Certiorarified Mandamus calling for the records or file bearing A.NO.03/2020- GST (Appeals) and after going into validity and legality thereof quashing the order in Appeal No.12/2020- GSt (Appeals) dated 28.7.2020 passed by the Additional Commissioner (Appeals) Salem Commissionerate and directing the respondents to sanction refund of Rs.11,66,956 (Refund claim at SR.NO 3. Paragraph PP ) along with interest. WP No.16789 of 2020 filed under Article 226 of the Constitution of India for issuance of a Writ of Certiorarified Mandamus calling for the records or file bearing C.No.V/18/41/2018-19-RF and after going into the validity and legality thereof quashing the order in original NO R-04/2020 dated 27.7.2020 passed by the respondent No 5 and directing the respondents to sanction refund of Rs 55,47,556 (Refund claim at SR. No.2, Paragraph PP) along with interest.

WP No.16788 of 2020 filed under Article 226 of the Constitution of India for issuance of a Writ of Certiorarified Mandamus calling for the records or file bearing C.No.V/18/41/2018-19-RF and after going into the validity and legality thereof quashing the order in original No.R-03/2020 dated 27.7.2020 passed by the respondent No.5 and directing the respondents to sanction refund of Rs 82,58,275 (Refund claim at SR. No 1, Paragraph PP) along with interest. WP No.12563 of 2020 filed under Article 226 of the Constitution of India for issuance of a Writ of Mandamus directing the respondents to permit the petitioner to revise its Form GST Tran - 1 filed on 07.10.2017 to enable the petitioner to take in its electronic credit ledger, the Cenvat credit of Rs 1,49,72,787/- lying in balance as on 30 June 2017 but inadvertently not carried forward in Form GST Tran – 1. For Petitioner : Mr.S.Muthu Venkataraman Page 2 of 4 https://www.mhc.tn.gov.in/judis WP Nos.16780 of 2020 etc. COMMON ORDER (Order of the Court was made by the Hon'ble Chief Justice) Learned counsel for the petitioner seeks to withdraw the writ petitions. 2. In view of the same, the writ petitions are dismissed as withdrawn. There will be no order as to costs. (SUSHRUT ARVIND DHARMADHIKARI, CJ.) (G.ARUL MURUGAN, J.) 02.07.2026 Neutral Citation : Yes/No tar To 1.The Secretary to Government Ministry of Finance Department of Revenue North Block New Delhi- 110 001 2.The Chairman

Central Board of Indirect Taxes & Customs North Block, New Delhi- 110 001 3.The Chairperson Goods & Service Tax Council 5th floor Tower- II Jeevan Bharati building Janapath Road, Cannaught Palace, New Delhi- 110 001 Page 3 of 4 https://www.mhc.tn.gov.in/judis WP Nos.16780 of 2020 etc. THE HON'BLE CHIEF JUSTICE AND G.ARUL MURUGAN , J. (tar) 4.The Commissioner of GST and Central Excise (IARC and R and T section) Salem Commissionerate, Salem- 636001 5.The Assistant Commissioner of GST & Central Excise Hosur- I Division Thally Road, Hosur- 635 109 WP Nos.16780 of 2020 etc. batch 02.07.2026 Page 4 of 4 https://www.mhc.tn.gov.in/judis

WP Nos.16780 of 2020 etc. IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 02.07.2026 CORAM THE HON'BLE MR.SUSHRUT ARVIND DHARMADHIKARI, CHIEF JUSTICE AND THE HON'BLE MR.JUSTICE G.ARUL MURUGAN WP Nos.16780, 12563, 16788, 16789, 16792 of 2020 WP No.16780 of 2020 Schaeffler India limited Rep by its Director Finance and CFO Office at 20, Royakottah Road Hosur- 635109 : Petitioner Versus 1.Union of India Rep by Secretary to Government Ministry of Finance Department of Revenue North Block New Delhi- 110 001 2.The Central Board of Indirect Taxes & Customs Rep by its chairman North Block New Delhi- 110 001 3.The Goods & Service Tax Council Rep by its Chairperson 5th floor Tower- II Jeevan Bharati building Janapath Road, Cannaught Palace, New Delhi- 110 001 4.The Commissioner of GST and Central Excise (IARC and R and T section) Salem Commissionerate, Salem- 636001 Page 1 of 4 https://www.mhc.tn.gov.in/judis WP Nos.16780 of 2020 etc. 5.The Assistant Commissioner of GST & Central Excise Hosur- I Division

Thally Road, Hosur- 635 109 : Respondents Prayer: WP No.16780 of 2020 filed under Article 226 of the Constitution of India for issuance of a Writ of Declaration declaring that Section 140 of the central Goods and Service Tax Act 2017 read with Rule 117 and 120-A of the Central Goods and Service Tax Rules 2017 insofar as it prescribes time period for filing/ revision of GSt TRAN-1 for transition of Cenvat Credit Ling in balance as on 31.7.2017 as arbitrary, invidiously discriminatroy and violative of Article 14, 19(1) (g) 245 and 246A of the Constitution of India. WP No.16792 of 2020 filed under Article 226 of the Constitution of India for issuance of a Writ of Certiorarified Mandamus calling for the records or file bearing A.NO.03/2020- GST (Appeals) and after going into validity and legality thereof quashing the order in Appeal No.12/2020- GSt (Appeals) dated 28.7.2020 passed by the Additional Commissioner (Appeals) Salem Commissionerate and directing the respondents to sanction refund of Rs.11,66,956 (Refund claim at SR.NO 3. Paragraph PP ) along with interest. WP No.16789 of 2020 filed under Article 226 of the Constitution of India for issuance of a Writ of Certiorarified Mandamus calling for the records or file bearing C.No.V/18/41/2018-19-RF and after going into the validity and legality thereof quashing the order in original NO R-04/2020 dated 27.7.2020 passed by the respondent No 5 and directing the respondents to sanction refund of Rs 55,47,556 (Refund claim at SR. No.2, Paragraph PP) along with interest.

WP No.16788 of 2020 filed under Article 226 of the Constitution of India for issuance of a Writ of Certiorarified Mandamus calling for the records or file bearing C.No.V/18/41/2018-19-RF and after going into the validity and legality thereof quashing the order in original No.R-03/2020 dated 27.7.2020 passed by the respondent No.5 and directing the respondents to sanction refund of Rs 82,58,275 (Refund claim at SR. No 1, Paragraph PP) along with interest. WP No.12563 of 2020 filed under Article 226 of the Constitution of India for issuance of a Writ of Mandamus directing the respondents to permit the petitioner to revise its Form GST Tran - 1 filed on 07.10.2017 to enable the petitioner to take in its electronic credit ledger, the Cenvat credit of Rs 1,49,72,787/- lying in balance as on 30 June 2017 but inadvertently not carried forward in Form GST Tran – 1. For Petitioner : Mr.S.Muthu Venkataraman Page 2 of 4 https://www.mhc.tn.gov.in/judis WP Nos.16780 of 2020 etc. COMMON ORDER (Order of the Court was made by the Hon'ble Chief Justice) Learned counsel for the petitioner seeks to withdraw the writ petitions. 2. In view of the same, the writ petitions are dismissed as withdrawn. There will be no order as to costs. (SUSHRUT ARVIND DHARMADHIKARI, CJ.) (G.ARUL MURUGAN, J.) 02.07.2026 Neutral Citation : Yes/No tar To 1.The Secretary to Government Ministry of Finance Department of Revenue North Block New Delhi- 110 001 2.The Chairman

Central Board of Indirect Taxes & Customs North Block, New Delhi- 110 001 3.The Chairperson Goods & Service Tax Council 5th floor Tower- II Jeevan Bharati building Janapath Road, Cannaught Palace, New Delhi- 110 001 Page 3 of 4 https://www.mhc.tn.gov.in/judis WP Nos.16780 of 2020 etc. THE HON'BLE CHIEF JUSTICE AND G.ARUL MURUGAN , J. (tar) 4.The Commissioner of GST and Central Excise (IARC and R and T section) Salem Commissionerate, Salem- 636001 5.The Assistant Commissioner of GST & Central Excise Hosur- I Division Thally Road, Hosur- 635 109 WP Nos.16780 of 2020 etc. batch 02.07.2026 Page 4 of 4 https://www.mhc.tn.gov.in/judis