WP No. 22737 of 2026 __________ Page1 of 4 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 24-06-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 22737 of 2026 and W.M.P.Nos.24670 & 24673 of 2026 Mkce Master Franchise India Private Limited Represented by its Director Mrs. Beena Natarajan, No. 118/2A2, Near Southern Textiles, Trichy Main Road, Ranganathapuram, Sulur, Coimbatore, Tamil Nadu - 641402. ..Petitioner(s) Vs The Deputy State Tax Officer -1 The Deputy Commercial Tax Officer, Karumathampatti Assessment Circle, O/o. The Assistant Commissioner (ST), Commercial Taxes Annex Buildings, II Floor, Dr. Balasundaram Road, Coimbatore -641 018 ..Respondent(s) PRAYER: Writ Petition filed under Article 226 of The Constitution of India praying for the issuance of a Writ of Certiorari, to call for the records from the file of the Respondent in impugned assessment order in GSTIN 33AAMCM4285C1ZI /2020-21 dated 10.02.2025 and Reference No.ZD330225090078H in GSTIN /ID 33AAMCM4285C1Z1 dated 10.02.2025 passed for the FY. 2020-21 and quash the same as arbitrary, erroneous on facts and violative of principles of natural justice. https://www.mhc.tn.gov.in/judis WP No. 22737 of 2026 __________ Page2 of 4 For Petitioner(s): Mr.M.Venkatesh for M/s. S. Arivazhagan For Respondent(s): Mr.R.Sethu Prabakaran, Government Counsel (Tax) ******** ORDER An order dated 10.02.2025 is assailed on the ground that the petitioner did not have a reasonable opportunity to contest the tax demand on merits. 2. Mr.R.Sethu Prabakaran, learned Government Counsel (Tax), accepts notice on behalf of the respondent. 3. On perusal of the impugned order, it is evident that such order was issued 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 25% of the disputed tax demand as a condition for remand. An endorsement to that effect has been made on the bundle. https://www.mhc.tn.gov.in/judis WP No. 22737 of 2026 __________ Page3 of 4 5. Subject to the condition that the petitioner remits 25% of the disputed tax demand within thirty days from the date of receipt of a copy of this order, the impugned order 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 25% 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. 24-06-2026 (1/2) Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To The Deputy State Tax Officer -1 The Deputy Commercial Tax Officer, Karumathampatti Assessment Circle, O/o. The Assistant Commissioner (ST), Commercial Taxes Annex Buildings, II Floor, Dr. Balasundaram Road, Coimbatore -641 018 https://www.mhc.tn.gov.in/judis WP No. 22737 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 22737 of 2026 and W.M.P.Nos.24670 & 24673 of 2026 24-06-2026 (1/2) https://www.mhc.tn.gov.in/judis