Sai Cashew Processors v. Deputy State Tax Officer -1
In favour of the assessee
The ruling in brief
Sai Cashew Processors challenged combined late fee and penalty before the High Court of Madras (WP Nos. 21603, 21609 and 21622 of 2026, decided 17 June 2026) for delayed filing of GST returns. Revenue imposed statutory late fee under Section 47 and an additional general penalty under Section 125 for the identical default. The court held that once a specific late fee is prescribed and levied for belated returns, a general penalty for the same default is unwarranted and amounts to impermissible double punishment under the scheme of the Act. Penalty orders were set aside while late fee collections remained intact. The decision favoured the assessee and aligns with Madras High Court jurisprudence on the interaction of Sections 47 and 125 for return delays.
For information only — not legal advice. Read the full judgment and applicable law before relying on this summary.
Provisions considered
- CGST S.125 — Section 125 of the Central Goods and Services Tax Act, 2017.
- CGST S.47 — Late fee for delayed filing of returns.
Source documents
Similar rulings
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