W.P.(MD) No.19516 of 2026 BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT DATED: 13.07.2026 CORAM: THE HONOURABLE MR.JUSTICE C.SARAVANAN W.P.(MD) No.19516 of 2026 and W.M.P.(MD) No.14428 of 2026 A.C.R.D.Rengarajan, S/o.Dharmaraj Nadar, No. 13, A.S.S.S.S. Road, Virudhunagar-626001. .. Petitioner - Vs. - The Assistant Commissioner ( ST), Virudhunagar-II Assessment Circle, Virudhunagar. .. Respondent Prayer: Writ Petition is filed under Article 226 of the Constitution of India, praying this court to issue a Writ of Certiorari calling for records pertaining to the impugned order passed by the Respondent vide his order in Temporary ID 332500004350TMP/2021-22 dated 03.03.2026 and quash the same as it is illegal, without jurisdiction and in gross violation of Principles of Natural Justice. For Petitioner : Mr.A.Satheesh Murugan 1/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No.19516 of 2026 For Respondent : Mr.R.Parthiban Counsel for the State of Tamil Nadu ORDER Heard Mr.A.Satheesh Murugan, learned counsel for the petitioner and Mr.R.Parthiban, learned counsel for the State of Tamil Nadu, for the respondent. 2. This Writ Petition is disposed of at the time of admission with the consent of the learned counsel for the petitioner and the learned counsel for the respondent.

3. In this Writ Petition, the Petitioner has challenged the impugned order passed by the respondent in Temporary ID 332500004350TMP/2021-22 dated 03.03.2026 under the provisions of the respective GST Enactments. 4. The Petitioner has not obtained registration and has not paid GST to the Government on the Seigniorage fee/Royalty for quarrying and 2/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No.19516 of 2026 transporting of mines and minerals under the Reverse Charge Mechanism (RCM). The Petitioner had also not made any contributions to the District Mineral Foundation Trust (DMFT). 5. Under similar circumstances, this Court has passed orders by remitting the case back subject to the outcome of the decision of the Hon'ble Supreme Court regarding the dispute relating to levy of GST on the Seigniorage fee/Royalty paid for quarrying mines and minerals. In this connection, a reference is made to the decision of this Court in S.Pichandhi, Proprietor of Sri Murugan Ready Mix Concrete and Blue Metal Industries, Vellore Vs. The Deputy State Tax Officer, Vellore Rural Assessment Circle, Vellore, in W.P.Nos.35883 and 35889 of 2025 dated 25.09.2025. Relevant portion of the order is reproduced below:-“3. In these Writ Petitions, the Petitioner has challenged the impugned Notices in FORM GST DRC-01A dated 16.06.2025 for the Tax Period 2021-2022 and 2020-2021 respectively.

4. The learned counsel for the Petitioner submits that the issue is now pending before the Hon'ble Supreme Court, as the dispute pertains to levy of GST on the Seigniorage fee/Royalty paid for quarrying and 3/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No.19516 of 2026 transporting mineral. 5. Considering the fact that the issue is pending before the Hon'ble Supreme Court, I am inclined to dispose of these Writ Petitions at the admission stage, by directing the Respondent to keep all the proceedings in abeyance. 6. The Respondent shall await the orders to be passed by the Hon'ble Supreme Court and thereafter proceed in accordance with law. The Petitioner shall however deposit 10% of the disputed tax as security, in line with the directions issued in the Petitioner's own case earlier.” 6. Considering the facts and circumstances of the above case in W.P.Nos.35883 and 35889 of 2025, which are almost identical to the facts of the present case, this Court is of the view that the aforesaid order will hold good in respect of the present Writ Petition also. Accordingly, this Writ Petition stand disposed of on the same terms. No costs. Connected Writ Miscellaneous Petition is closed. 13.07.2026 2/3 Index : Yes / No NCC : Yes/No PJL 4/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No.19516 of 2026 To The Assistant Commissioner ( ST), Virudhunagar-II Assessment Circle, Virudhunagar. 5/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No.19516 of 2026 C.SARAVANAN, J. PJL

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W.P.(MD) No.19516 of 2026 BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT DATED: 13.07.2026 CORAM: THE HONOURABLE MR.JUSTICE C.SARAVANAN W.P.(MD) No.19516 of 2026 and W.M.P.(MD) No.14428 of 2026 A.C.R.D.Rengarajan, S/o.Dharmaraj Nadar, No. 13, A.S.S.S.S. Road, Virudhunagar-626001. .. Petitioner - Vs. - The Assistant Commissioner ( ST), Virudhunagar-II Assessment Circle, Virudhunagar. .. Respondent Prayer: Writ Petition is filed under Article 226 of the Constitution of India, praying this court to issue a Writ of Certiorari calling for records pertaining to the impugned order passed by the Respondent vide his order in Temporary ID 332500004350TMP/2021-22 dated 03.03.2026 and quash the same as it is illegal, without jurisdiction and in gross violation of Principles of Natural Justice. For Petitioner : Mr.A.Satheesh Murugan 1/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No.19516 of 2026 For Respondent : Mr.R.Parthiban Counsel for the State of Tamil Nadu ORDER Heard Mr.A.Satheesh Murugan, learned counsel for the petitioner and Mr.R.Parthiban, learned counsel for the State of Tamil Nadu, for the respondent. 2. This Writ Petition is disposed of at the time of admission with the consent of the learned counsel for the petitioner and the learned counsel for the respondent.

3. In this Writ Petition, the Petitioner has challenged the impugned order passed by the respondent in Temporary ID 332500004350TMP/2021-22 dated 03.03.2026 under the provisions of the respective GST Enactments. 4. The Petitioner has not obtained registration and has not paid GST to the Government on the Seigniorage fee/Royalty for quarrying and 2/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No.19516 of 2026 transporting of mines and minerals under the Reverse Charge Mechanism (RCM). The Petitioner had also not made any contributions to the District Mineral Foundation Trust (DMFT). 5. Under similar circumstances, this Court has passed orders by remitting the case back subject to the outcome of the decision of the Hon'ble Supreme Court regarding the dispute relating to levy of GST on the Seigniorage fee/Royalty paid for quarrying mines and minerals. In this connection, a reference is made to the decision of this Court in S.Pichandhi, Proprietor of Sri Murugan Ready Mix Concrete and Blue Metal Industries, Vellore Vs. The Deputy State Tax Officer, Vellore Rural Assessment Circle, Vellore, in W.P.Nos.35883 and 35889 of 2025 dated 25.09.2025. Relevant portion of the order is reproduced below:-“3. In these Writ Petitions, the Petitioner has challenged the impugned Notices in FORM GST DRC-01A dated 16.06.2025 for the Tax Period 2021-2022 and 2020-2021 respectively.

4. The learned counsel for the Petitioner submits that the issue is now pending before the Hon'ble Supreme Court, as the dispute pertains to levy of GST on the Seigniorage fee/Royalty paid for quarrying and 3/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No.19516 of 2026 transporting mineral. 5. Considering the fact that the issue is pending before the Hon'ble Supreme Court, I am inclined to dispose of these Writ Petitions at the admission stage, by directing the Respondent to keep all the proceedings in abeyance. 6. The Respondent shall await the orders to be passed by the Hon'ble Supreme Court and thereafter proceed in accordance with law. The Petitioner shall however deposit 10% of the disputed tax as security, in line with the directions issued in the Petitioner's own case earlier.” 6. Considering the facts and circumstances of the above case in W.P.Nos.35883 and 35889 of 2025, which are almost identical to the facts of the present case, this Court is of the view that the aforesaid order will hold good in respect of the present Writ Petition also. Accordingly, this Writ Petition stand disposed of on the same terms. No costs. Connected Writ Miscellaneous Petition is closed. 13.07.2026 2/3 Index : Yes / No NCC : Yes/No PJL 4/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No.19516 of 2026 To The Assistant Commissioner ( ST), Virudhunagar-II Assessment Circle, Virudhunagar. 5/6 https://www.mhc.tn.gov.in/judis W.P.(MD) No.19516 of 2026 C.SARAVANAN, J. PJL

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