WP No. 21631 of 2026 __________ Page1 of 4 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 16-06-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 21631 of 2026 and W.M.P.Nos.23418 & 23419 of 2026 Rajendran Subbarayan Proprietor of Sri Maruthi Cotton Mill No.5/199/A, Karamadai Road, Kurumbapalaiyam Karegoundenpalayam, Coimbatore TamilNadu-641697 ..Petitioner(s) Vs 1. The Deputy Commissioner C T Commercial Taxes building, Dr. Balasundaram Road, Coimbatore, Tamil nadu 641 018 2. Commercial Tax Officer Saravanampatti East Coimbatore III, TamilNadu ..Respondent(s) PRAYER: Writ Petition filed under Article 226 of The Constitution of India praying for the issuance of a Writ of Certiorarified Mandamus, Calling for the records in Reference No. ZD331225008918E dated 01.12.2025 on the file of the 1st Respondent relating to FY 2019-20 and quash the same and consequently direct the 1st Respondent to accept, number and hear the appeal on merits and de freeze the bank account of the petitioner. https://www.mhc.tn.gov.in/judis WP No. 21631 of 2026 __________ Page2 of 4 For Petitioner(s): Mr.G. Lokeshwaran For Respondent(s): Ms.G.Dhana Madhri, Government Counsel (Tax) ********** ORDER An appellate order dated 01.12.2025 is assailed on the ground that the appeal was rejected solely on the ground of limitation. 2. Ms.G.Dhana Madhri, learned Government Counsel (Tax), accepts notice on behalf of the respondents. 3. On perusal of the order-in-original dated 31.08.2024, it is evident that such order was issued after considering the reply but without hearing the petitioner. The writ petition has been filed after the period of limitation expired. 4. On instructions, learned counsel for the petitioner agrees to remit 50% of the disputed tax demand as a condition for remand. An endorsement to that effect has been made on the bundle. 5. Subject to the condition that the petitioner remits 50% of the disputed tax demand within thirty days from the date of receipt of a copy of this order, https://www.mhc.tn.gov.in/judis WP No. 21631 of 2026 __________ Page3 of 4 by moulding the relief, the original order dated 31.08.2024 is set aside and the matter is remanded for re-consideration. After providing a reasonable opportunity to the petitioner, a fresh order shall be issued within three months from the date of remittance of 50% of the disputed tax demand. 6. The writ petition is disposed of on the above terms. Consequently, connected writ miscellaneous petitions are closed. There shall be no order as to costs. 16-06-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To 1. The Deputy Commissioner C T Commercial Taxes building, Dr. Balasundaram Road, Coimbatore, Tamil nadu 641 018 2. Commercial Tax Officer Saravanampatti East Coimbatore III, TamilNadu https://www.mhc.tn.gov.in/judis WP No. 21631 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 21631 of 2026 and W.M.P.Nos.23418 & 23419 of 2026 16-06-2026 https://www.mhc.tn.gov.in/judis