WP No. 22510 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. 22510 of 2026 and W.M.P.Nos.24438 & 24439 of 2026 Chandrasekaran Murugaiyan Proprietor, Tvl. C.S. Tex, 366/1, Bharathi Nagar, Kovai Road, Annur, Coimbatore, Tamil Nadu- 641 653. ..Petitioner(s) Vs Deputy State Tax Officer -1 Annur Assessment Circle, Annur, Coimbatore- III, Coimbatore, Tamil Nadu. ..Respondent(s) PRAYER: Writ Petition filed under Article 226 of The Constitution of India praying for the issuance of a Writ of Certiorari, call for the records on the files of the Respondent herein in GSTIN 33AICPC3138M1ZJ/2021-22 dated 19.12.2025, order under section 73 and the summary of the order in FORM GST DRC-07 both dated 19.12.2025 issued in Reference No. ZD3312253149597 and quash the same. For Petitioner(s): Mr.Jayaprathap A N R https://www.mhc.tn.gov.in/judis WP No. 22510 of 2026 __________ Page2 of 4 For Respondent(s): Ms.G.Dhana Madhri, Government Counsel (Tax) *********** ORDER An order dated 19.12.2025 is assailed on the ground that the petitioner did not have a reasonable opportunity to contest the tax demand on merits. 2. Ms.G.Dhana Madhri, 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. 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. https://www.mhc.tn.gov.in/judis WP No. 22510 of 2026 __________ Page3 of 4 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 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To Deputy State Tax Officer -1 Annur Assessment Circle, Annur, Coimbatore- III, Coimbatore, Tamil Nadu. https://www.mhc.tn.gov.in/judis WP No. 22510 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 22510 of 2026 and W.M.P.Nos.24438 & 24439 of 2026 24-06-2026 https://www.mhc.tn.gov.in/judis