Vijay had challenged the penalty, claiming he had declared an income of ₹35.42 crore for the financial year 2016–17.

Contradicting his claim, the Income Tax department, which conducted raids in 2015, alleged that the Tamilaga Vettri Kazhagam (TVK) chief failed to disclose ₹15 crore earned from the film Puli.

Following the penalty order issued on June 30, 2022, Vijay moved the High Court and secured an interim stay on August 16, 2022, from a single-judge bench.

He argued that the penalty should have been imposed by June 30, 2019, and contended that the order was liable to be set aside as it was issued beyond the prescribed time limit.

The Income Tax department, however, sought dismissal of the plea, asserting that the penalty was imposed in accordance with provisions of the IT Act.