Reverse charge under GST cannot change the statutorily liable recipient, and the impugned order was set aside.

Reverse charge under the IGST framework cannot be used to substitute a taxable person different from the recipient contemplated by Section 5(3) of the Integrated Goods and Services Tax Act, 2017. Applying the Supreme Court's ruling in Mohit Minerals, the Madras HC treated the GST challenge as covered by binding precedent, held that the notification could not alter the statutorily prescribed recipient-liability structure, and allowed the writ petition, with the impugned order not surviving.

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Issues: Challenge to the impugned GST order and the applicability of reverse charge in light of the binding precedent on the recipient liable to tax.

Analysis: The writ petition was treated as covered by the decision of the Supreme Court in Mohit Minerals, which held that reverse charge under the IGST framework fixes the taxable person by the statute and that the notification cannot specify a different taxable person than the recipient contemplated by Section 5(3) of the Integrated Goods and Services Tax Act, 2017. Following the same view, the Court disposed of the petition in terms of the earlier batch decision.

Conclusion: The impugned order did not survive and the writ petition was allowed.

Ratio Decidendi: In matters of reverse charge, a notification cannot alter the recipient statutorily prescribed as the taxable person under Section 5(3) of the Integrated Goods and Services Tax Act, 2017.

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