WP No. 23613 of 2026 __________ Page1 of 4 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 02-07-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 23613 of 2026 and W.M.P.Nos.25569 & 25571 of 2026 Mr Mathiyazhagan Pattusamy Proprietor of M/s Kavitha Agencies No.1, Anna Nedunchalai, Annal Ambedkar Nagar, Perungudi Chennai 600 096. ..Petitioner(s) Vs The State Tax officer Shollinganallur Assessment Circle, Room No 240, 2nd Floor, Integrated Commercial Tax and Registration buildings, Nandanam, Chenani 600 035 ..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 of the respondent Show Cause Notice in DRC-01 dated 29.08.2025 and the consequential order in GSTIN33BNPPM2625C2Z7/ 2021-2022 along with DRC-07 dated 15.11.2025 and rectification order in GSTIN33BNPPM2625C2Z7/2021-2022 vide Ref.No.ZD3302260150516 dated 03.02.2026 rejecting the rectification application dated 01.12.2025 and quash the same as illegal, unjustified and without jurisdiction. For Petitioner(s): Mr.V.Sundareswaran https://www.mhc.tn.gov.in/judis WP No. 23613 of 2026 __________ Page2 of 4 For Respondent(s): Mr.R.Sethu Prabakaran, Government Counsel (Tax) ********** ORDER An order dated 29.08.2025 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. 23613 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. 02-07-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To The State Tax officer Shollinganallur Assessment Circle, Room No 240, 2nd Floor, Integrated Commercial Tax and Registration buildings, Nandanam, Chenani 600 035 https://www.mhc.tn.gov.in/judis WP No. 23613 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 23613 of 2026 and W.M.P.Nos.25569 & 25571 of 2026 02-07-2026 https://www.mhc.tn.gov.in/judis