WP No. 23229 of 2026 __________ Page1 of 4 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 30-06-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 23229 of 2026 and W.M.P.Nos.25187 & 25188 of 2026 Tvl Sri Balalji Traders Represented by its Proprietor Sakuthala 60, Work Shop Corner, East Main Road Mettur Dam, Salem 636401 ..Petitioner(s) Vs Deputy Tax Officer 1 (Also known as Deputy commercial tax officer) Mettur, Assessment circle, Salem ..Respondent(s) PRAYER: Writ Petition filed under Article 226 of The Constitution of India praying for the issuance of a Writ of Certiorari, calling for the records on the files of the Respondent herein in his Order in FORM GST DRC - 07 with Reference No. ZD3309251663091 dated 15.09.2025 issued along with the detailed order in GSTIN NO.33CSCPS8904B1ZW/2018-2019 dated 15.09.2025 and quash the same. For Petitioner(s): Mr.N Chandirasekar For Respondent(s): Ms.G.Dhana Madhri, Government Counsel (Tax) ************* https://www.mhc.tn.gov.in/judis WP No. 23229 of 2026 __________ Page2 of 4 ORDER An order dated 15.09.2025 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. 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. https://www.mhc.tn.gov.in/judis WP No. 23229 of 2026 __________ Page3 of 4 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. 30-06-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To Deputy Tax Officer 1 (Also known as Deputy commercial tax officer) Mettur, Assessment circle, Salem https://www.mhc.tn.gov.in/judis WP No. 23229 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 23229 of 2026 and W.M.P.Nos.25187 & 25188 of 2026 30-06-2026 https://www.mhc.tn.gov.in/judis