GST on seigniorage under reverse charge left subject to connected writ directions pending Constitution Bench ruling on royalty

GST liability under the reverse charge mechanism on seigniorage paid to the Government was challenged in a writ petition. The Madras HC referred to directions in connected writ petitions requiring adjudication on merits while keeping adjudication orders in abeyance and barring recovery until the Nine Judge Constitution Bench decides the nature of royalty. In light of that binding course, the petition was not separately decided on merits and was disposed of accordingly, with pending miscellaneous petitions closed.

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Issues: Whether the assessment order imposing GST under the reverse charge mechanism on seigniorage paid to the Government required independent adjudication in this writ petition.

Analysis: The petition challenged the assessment order in the context of GST liability on seigniorage. The Court noted the directions issued in the connected batch of writ petitions, which provided for adjudication on merits but kept the adjudication orders in abeyance and barred recovery until the Nine Judge Constitution Bench decides the nature of royalty. In view of that binding course, the present writ petition was not separately decided on merits.

Outcome: The writ petition was disposed of in terms of the directions issued in the connected batch, with pending miscellaneous petitions closed.

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