WP/12632/2026 of M/S. ULTRA READYMIX CONCRETE P LTD Vs THE ASSISTANT COMMISSIONER (ST)
W.P.Nos.12632 and 12637 of 2026
IN THE HIGH COURT OF JUDICATURE AT MADRAS
DATED : 02.04.2026
CORAM :
THE HONOURABLE MR.JUSTICE C.SARAVANAN
W.P.Nos.12632 and 12637 of 2026
and
W.M.P.Nos.13787, 13788, 13791 and 13793 of 2026
M/s.Ultra Readymix Concrete (P) Ltd.,
Represented by its Chief Executive Officer
K.R.Ananth Kumar ... Petitioner in both W.Ps
Vs.
The Assistant Commissioner (ST),
Gandhipuram Assessment Circle,
Coimbatore. ... Respondent in both W.Ps
Prayer in W.P.No.12632 of 2026: Writ Petition filed under Article 226 of the
Constitution of India, for issuance of a Writ of Certiorari, to cal l for the
records of the respondent in his proceeding in GSTIN:
33AAACU7836K1Z2/2020-2021 and quash the proceeding dated 20.02.2026
passed therein.
Prayer in W.P.No.12637 of 2026: Writ Petition filed under Article 226 of the
Constitution of India, for issuance of a Writ of Certiorari, to cal l for the
records of the respondent in his proceeding in GSTIN:
33AAACU7836K1Z2/2021-2022 and quash the proceeding dated 20.02.2026
passed therein.
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W.P.Nos.12632 and 12637 of 2026
For Petitioner : Mr.B.Raveendran
(In both W.Ps)
For Respondent : Mr.V.Prashanth Kiran
(In both W.Ps) Government Advocate
COMMON ORDER
Mr.V.Prashanth Kiran, learned Government Advocate takes notice
for the Respondent.
2. These Writ Petitions are being disposed of at the time of
admission with the consent of the learned counsel for the Petitioner and t he
learned Government Advocate for the Respondent.
3. In these Writ Petitions, the Petitioner has challenged the
impugned order(s) passed by the Respondent in GSTIN:
33AAACU7836K1Z2/2020-2021 and GSTIN: 33AAACU7836K1Z2/2021-
2022 dated 20.02.2026 (digitally signed on 21.02.2026) under Section 74 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
transporting of mines and minerals under the Reverse Charge Mechanism
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W.P.Nos.12632 and 12637 of 2026
(RCM). The Petitioner had also not made any contributions to the Dist rict
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 t he 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 transporting mineral.
5. Considering the fact that the issue is
pending before the Hon'ble Supreme Court, I am
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W.P.Nos.12632 and 12637 of 2026
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 cases, this Court is of the view that the aforesaid order will hold
good in respect of the present Writ Petitions also. Accordingly, these Writ
Petitions stand disposed of on the same terms. No costs. Connected Writ
Miscellaneous Petitions are closed.
02.04.2026
Neutral Citation : Yes / No
arb
To:
The Assistant Commissioner (ST),
Gandhipuram Assessment Circle,
Coimbatore.
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W.P.Nos.12632 and 12637 of 2026
C.SARAVANAN, J.
arb
W.P.Nos.12632 and 12637 of 2026
and
W.M.P.Nos.13787, 13788, 13791 and 13793 of 2026
02.04.2026
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