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[Cites 6, Cited by 0]

Madras High Court

M/S. Abt Limited vs The Union Of India on 24 April, 2025

Author: Anita Sumanth

Bench: Anita Sumanth

                                                                                       W.P.No.19202 of 2013



                                  IN THE HIGH COURT OF JUDICATURE AT MADRAS

                                                    DATED: 24.04.2025

                                                          CORAM :

                                  THE HONOURABLE DR.JUSTICE ANITA SUMANTH
                                                    and
                                  THE HONOURABLE MR.JUSTICE C.KUMARAPPAN

                                               W.P.No. 19202 of 2013

                     M/s. ABT Limited,
                     180, Race Course Road,
                     Coimbatore – 641 018,
                     Rep. by its Chief Executive.                                             .. Petitioner

                                                               vs


                     1.The Union of India,
                       Rep. by its Secretary,
                       Ministry of Finance,
                       Department of Revenue,
                       New Delhi.

                     2.The Central Board of Excise and
                        Customs, North Block,
                       New Delhi – 110 001.

                     3.The Commissioner of Service Tax,
                       6/7 ATD Street, Race Course,
                       Coimbatore – 641 018.

                     4.The Additional Commissioner of Service Tax,
                       6/7 ATD Street, Race Course,
                       Coimbatore – 641 018.                                               .. Respondents


                     Prayer : Writ Petition filed under Article 226 of the Constitution of India

                     praying to issue a writ of declaration declaring that the provisions of Rule

                     5(1) of the Service Tax (Determination of Value) Rules, 2006 is beyond

                     the legislative competence of the Union of India under Article 248 of the


                     1/4



https://www.mhc.tn.gov.in/judis              ( Uploaded on: 24/04/2025 09:03:41 pm )
                                                                                                    W.P.No.19202 of 2013


                     Constitution of India and void being repugnant to Articles 14 and 19(1)(a)

                     of the Constitution of India and accordingly unenforceable, null and void.


                                  For Petitioner        :        No appearance

                                  For Respondents       :        Mr.A.P.Srinivas
                                                                 Senior Standing Counsel

                                                                ORDER

(Order of the Court was made by Dr. ANITA SUMANTH.,J) Petitioner is not represented.

2. However, Mr.A.P.Srinivas, learned Senior Standing Counsel for the Department, would fairly bring to our notice that the issue arising in this writ petition being a declaration that the provisions of Rule 5(1) of the Service Tax (Determination of Value) Rules, 2006 is ultra vires, has been decided by the Supreme Court in the case of Union of India v Intercontinental Consultants and Technocrats Pvt Ltd [2018 (10) GSTL 401(SC)] adverse to the Revenue. This judgment has also been followed by this Court in M/s. Sri Chidambaram and Co., v Union of India and others [ W.P.Nos. 20832 & 40707 of 2016 dated 20.11.2024.]

3. In light of the same, this writ petition is liable to be allowed and we do so. No costs.

[A.S.M., J] [C.K., J] 24.04.2025 Index:Yes/No Neutral Citation:Yes/No ssm 2/4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 24/04/2025 09:03:41 pm ) W.P.No.19202 of 2013 To

1.The Secretary, Ministry of Finance, Department of Revenue, New Delhi.

2.The Central Board of Excise and Customs, North Block, New Delhi – 110 001.

3.The Commissioner of Service Tax, 6/7 ATD Street, Race Course, Coimbatore – 641 018.

4.The Additional Commissioner of Service Tax, 6/7 ATD Street, Race Course, Coimbatore – 641 018.

3/4

https://www.mhc.tn.gov.in/judis ( Uploaded on: 24/04/2025 09:03:41 pm ) W.P.No.19202 of 2013 DR. ANITA SUMANTH.,J.

and C.KUMARAPPAN.,J.

ssm W.P.No.19202 of 2013 24.04.2025 4/4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 24/04/2025 09:03:41 pm )