WP No. 22905 of 2026 __________ Page1 of 4 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 25-06-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 22905 of 2026 and W.M.P.Nos.24828 & 24829 of 2026 Tvl SRI NIVASHINI COTTONS Represented by Its Proprietor Mr N.Marudhachalamoorthy S/o Nanjappa Mudali No.3/176, Sri Andavar Mills, Coimbatore Road, Annur ,Coimbatore 641653 ..Petitioner(s) Vs The Assistant Commissioner ST Avinashi Assessment Circle Avinash, Tiruppur District ..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 impugned Order dated 30.04.2024 in Form GST DRC-07 bearing Reference No.ZD330424253368D along with its annexure in Petitioners GSTIN 33BHHPM6918E1ZD for the FY 2018-2019 passed by the respondent and quash the same. For Petitioner(s): Mr.Sathiyaraj E. https://www.mhc.tn.gov.in/judis WP No. 22905 of 2026 __________ Page2 of 4 For Respondent(s): Mr.R.Sethu Prabakaran, Government Counsel (Tax) ********* ORDER An order dated 30.04.2024 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 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. 22905 of 2026 __________ Page3 of 4 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 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. 25-06-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To The Assistant Commissioner ST Avinashi Assessment Circle Avinash, Tiruppur District https://www.mhc.tn.gov.in/judis WP No. 22905 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 22905 of 2026 and W.M.P.Nos.24828 & 24829 of 2026 25-06-2026 https://www.mhc.tn.gov.in/judis