WP No. 46498 of 2025 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 28-11-2025 CORAM THE HON'BLE MR JUSTICE C. SARAVANAN WP No. 46498 of 2025 AND WMP Nos. 51856 and 51857 of 2025 M/s.Woodstock, Rep By Its Proprietor, Mathangi Srinivasamurthi, No.18/12, Lakshmanan Street, T.Nagar, Chennai-600 017. ..Petitioner(s) Vs The Deputy State Tax Officer Pondy Bazaar Assessment Circle, No.46-iiird Floor, Greenways Road, Chennai-600 028. ..Respondent(s) PRAYER – This Writ Petition is filed under Article 226 of the Constitution of India, seeking a Writ of Certiorari, calling for the records of the respondent in GSTIN 33AAMPM7166P1ZY/2019-20 and quash the proceeding dated 03.08.2024 passed therein. __________ p. 2 WP No. 46498 of 2025 For Petitioner(s): Mr.Raveendran B For Respondent(s): Ms.P.Selvi, Government Advocate O R D E R Ms.P.Selvi, learned Government Advocate takes notice for the Respondent. 2. This Writ Petition is being disposed of at the stage of admission itself with the consent of the learned counsel for the Petitioner and the learned Government Advocate for the Respondent. 3. In this Writ Petition, the Petitioner has challenged the impugned Order dated 03-08-2024 of the Respondent, which was preceded by a Show Cause Notice in Form GST DRC-01 dated 24.05.2024 wherein the Petitioner was called upon to appear for personal hearing. However, the Petitioner had not taken advantage of the same and thus, suffered the impugned Order dated 03.08.2024. __________ p. 3 WP No. 46498 of 2025 4. It is noticed that the limitation for filing an appeal under Section 107 of the respective GST Enactments, 2017 against the impugned Order has already expired. The present Writ Petition has been filed only on 26.11.2025. 5. Under similar circumstances, Orders have been quashed and cases have been remitted back to pass a fresh order on terms subject to such Assessee depositing 25% to 100% of the disputed tax depending upon the length of delay in approaching the Court. I do not find any reason to take a different view in this case. 6. Therefore, to balance the interest of both parties viz., the Assessee and the Revenue, the case is remitted back to the Respondent to pass a fresh order subject to the Petitioner depositing 50% of the disputed tax in cash from the Petitioner's Electronic Cash Register within a period of thirty (30) days from the date of receipt of a copy of this order. __________ p. 4 WP No. 46498 of 2025 7. Within such time, the Petitioner shall also file a reply to the Show Cause Notice in GST DRC-01 dated 24.05.2024 together with requisite documents to substantiate the case by treating the impugned Order dated 03.08.2024 as an addendum to the Show Cause Notice dated 24.05.2024. 8. In case the Petitioner complies with the above stipulations, the Respondent shall proceed to pass a final order on merits and in accordance with law as expeditiously as possible, preferably, within a period of three (3) months of such reply/pre-deposit. Subject to the Petitioner complying with the above stipulations, the attachment of the bank account of the Petitioner shall also stand automatically vacated. 9. It is made clear that bank attachment shall be lifted subject to the deposit of 50% of the disputed tax as ordered above and no other amount is in arrears barring the amount demanded under the impugned Order. __________ p. 5 WP No. 46498 of 2025 10. In case the Petitioner fails to comply with any of the stipulations, the Respondent is at liberty to proceed against the Petitioner to recover the tax in accordance with law as if this Writ Petition was dismissed in limine today. 11. Needless to state, before passing any such order, the Respondent shall give due notice to the Petitioner. 12. This Writ Petition stands disposed of with the above observations. No costs. Connected Writ Miscellaneous Petitions are closed. 28-11-2025 Index: Yes/No (2/3) Speaking/Non-speaking order GSA To The Deputy State Tax Officer, Pondy Bazaar Assessment Circle, __________ p. 6 WP No. 46498 of 2025 No.46 – III Floor, Greenways Road, Chennai 600 028. __________ p. 7 WP No. 46498 of 2025 C.SARAVANAN J. GSA WP No. 46498 of 2025 AND WMP Nos. 51856 and 51857 of 2025 __________ p. 8 WP No. 46498 of 2025 28-11-2025 (2/3) __________