WP No. 23483 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. 23483 of 2026 and W.M.P.No.25469 of 2026 M.L.Auto Parts (Represented by its Partner Ms.Sneha Jambukumar) 86/24, East Raja Street, Kanchipuram, Tamil Nadu - 631502. ..Petitioner(s) Vs The State Tax Officer, kancheepuram (Rural) Assessment Circle, C.T.Building, kancheepuram collectorate campus, kancheepuram - 631501. ..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 FORM GST DRC - 07 with Reference No. ZD3312250984178 dated 06.12.2025 along with detailed order in GSTIN- 33ABMFM9932G1ZY/2021-22 dated 06.12.2025, for the tax period APR 2021 MAR 2022 and quash the same. For Petitioner(s): Mr.B Syed Abdul Wakeel For Respondent(s): Mr.R.Sethu Prabakaran, Government Counsel (Tax) ********** https://www.mhc.tn.gov.in/judis WP No. 23483 of 2026 __________ Page2 of 4 ORDER An order dated 06.12.2025 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. Learned counsel for the petitioner submits that the entire amount demanded under the impugned order was recovered from the petitioner upon attachment of the bank amount. This aspect is required to be verified and confirmed. 5. Subject to verifying and confirming that the entire amount demanded under the impugned order towards tax, interest and penalty was recovered from the petitioner, 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 verifying and https://www.mhc.tn.gov.in/judis WP No. 23483 of 2026 __________ Page3 of 4 confirming that the entire amount demanded under the impugned order had been recovered. 6. The writ petition is disposed of on the above terms. Consequently, connected writ miscellaneous petition is 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 State Tax Officer, kancheepuram (Rural) Assessment Circle, C.T.Building, kancheepuram collectorate campus, kancheepuram - 631501. https://www.mhc.tn.gov.in/judis WP No. 23483 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 23483 of 2026 and W.M.P.No.25469 of 2026 01-07-2026 https://www.mhc.tn.gov.in/judis