After Pan Products Company Agrees to Deposit ₹3.5 Crore Of GST Demand, Supreme Court Stays Coercive Action

The Supreme Court has directed Simla Gomti Pan Products Pvt. Ltd. to deposit Rs 3.5 crore in a GST dispute and ordered that no coercive action be taken against it for now.

A bench of Justice J.B. Pardiwala and Justice K.V. Viswanathan was hearing the company's challenge to a November 3, 2025, judgment of the Allahabad High Court, which had refused to entertain its writ petition.

The company had earlier approached the High Court against assessment orders for 2021–22 and 2022–23, contending that they were passed ex parte without giving it access to key documents, including the SIB report.

The total liability under the assessment orders, including interest and penalty, is around Rs 159 crore, while the principal tax demand is about Rs 67 crore.

The High Court declined to intervene, pointing out that the company had an alternative remedy of filing an appeal under the GST law, which requires a 10% pre-deposit of the tax demand.

Before the Supreme Court, Senior Advocate Mukul Rohatgi, appearing for the company, submitted that although the department said documents were uploaded, they were placed on a different portal and could not be accessed.

As a result, the company could not respond to the show cause notices, and the assessment orders were passed without its participation. The total liability, including interest and penalty, has now touched around Rs 159 crore.

Recording the submission, the court observed: “Mr. Rohatgi would submit that the two assessment orders could be said to be ex parte orders because his client had no opportunity to participate in the assessment proceedings.”

The court then directed the company to deposit Rs 3.5 crore within two weeks. It also ordered that once the amount is deposited, notice will be issued to the tax authorities, and no coercive steps will be taken in the meantime.

For Petitioner: Senior Advocate Mukul Rohatgi, with Advocates Ujjawal Anand Sharma, Prashant Srivarajan, Aditya Narayan Sharma, Sourabh Goyal, Abhishek and Vritti Jain; AOR D. Kumanan