WP No. 23466 of 2026 __________ Page1 of 4 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 01-07-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 23466 of 2026 and W.M.P.Nos.25458 & 25459 of 2026 Ganapathy Coirs Rep. by its Proprietor Karthika Divi No.14/162-4,Avangalaipalayam, Nallroad, Kangeyan,Tiruppur-638701 ..Petitioner(s) Vs The Assistant Commissioner (ST)(FAC) Kangeyam Assessment Circle, Tiruppur Road, Kangeyam, Tiruppur District. ..Respondent(s) PRAYER: Writ Petition filed under Article 226 of The Constitution of India praying for the issuance of a Writ of Certiorarified Mandamus, call for the records in impugned assessment order passed in GSTIN 33FYKPK8067C1Z9/ 2021-2022 Dated 26.12.2025, and notice of attachment in form GST DRC-13 dated 30.04.2026 issued by the respondent herein and quash the same as illegal and consequently direct the respondent to lift the attachment of the petitioners bank accounts and to provide relied upon documents in show cause notice dated 26.09.2025. https://www.mhc.tn.gov.in/judis WP No. 23466 of 2026 __________ Page2 of 4 For Petitioner(s): Mr.V.Janarthanan For Respondent(s): Mr.R.Sethu Prabakaran, Government Counsel (Tax) ********** ORDER An order dated 26.12.2025 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. 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, https://www.mhc.tn.gov.in/judis WP No. 23466 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 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. 01-07-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To The Assistant Commissioner (ST)(FAC) Kangeyam Assessment Circle, Tiruppur Road, Kangeyam, Tiruppur District. https://www.mhc.tn.gov.in/judis WP No. 23466 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 23466 of 2026 and W.M.P.Nos.25458 & 25459 of 2026 01-07-2026 https://www.mhc.tn.gov.in/judis