Proven double taxation of turnover is a rectifiable mistake under Section 161 of the GST Act.

The appellant had separate GST registrations for its Tirunelveli factory and Coimbatore registered office.

For April 2021 to March 2022, an assessment concerning the Tirunelveli unit was made on 21 April 2025 and was under statutory appeal.

The appellant alleged that turnover assessed for that unit was also included in the Coimbatore assessment.

It sought rectification under Section 161 of the Tamil Nadu Goods and Services Tax Act, 2017, but the assessing authority rejected the request as an impermissible review.

The writ court directed a 25% pre-deposit and remanded the matter for fresh consideration; the appellant appealed.

The High Court confined its consideration to the alleged double taxation.

The Court applied Section 161 of the Tamil Nadu Goods and Services Tax Act, 2017, concerning rectification of mistakes.

It held that, where an assessee establishes that the same turnover has been brought to tax in more than one assessment, the overlap may amount to a rectifiable mistake under that provision.

The tax authority should consider the assessee’s records holistically, even where the units are assessed under different charges, so that the turnover is taxed only once.

No precedent was cited.

The appellant’s rectification request had referred generally to ₹64,29,38,464 as turnover already subject to tax, but the Court could not determine from the material whether that was the precise amount assessed for the Tirunelveli unit or the extent of any overlap.

Nevertheless, if the appellant could establish that turnover assessed in Tirunelveli had also been included in the Coimbatore assessment, that issue was capable of rectification under Section 161.

The Department’s records should be examined together to determine whether the same turnover had been taxed twice.

The appellant was therefore directed to provide a computation of the overlap for the assessing officer’s consideration.

The order dated 28 October 2025 was set aside to the extent of the alleged double taxation, and the second respondent was directed to hear the appellant, examine the overlap, re-work the turnover if warranted, and pass fresh orders on that issue alone within four weeks of the personal hearing.

The appellant was permitted to appear on 22 October 2026 and was given four weeks from the judgment to challenge the assessment on other issues in accordance with law.

No costs were awarded, and the connected miscellaneous petition was closed.