WP No. 23698 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. 23698 of 2026 and W.M.P.Nos.25665 & 25666 of 2026 Algrace Garments Rep by its proprietor Mohamed Wassim, 241, MGR Nagar,1st Opp, P N Road,Tiruppur - 641602. ..Petitioner(s) Vs Deputy State Tax Officer I Lakshminagar Assessment Circle, Tiruppur II First Floor, emperor building, no.16, indiranagar 1st street, avinashi road, tiruppur - 641603. ..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 relating to the Order No. 232 / 2025 / Al dated 05.01.2026 bearing Reference Number ZD330126020527S in form DRC 07 issued by the respondent in respect of GSTIN33ABCPW2967K1Z7/2024/25, and quash the same as illegal, arbitrary, contrary to material facts and in violation of the principles of natural justice. For Petitioner(s): Mr.Adithya Reddy For Respondent(s): Mr.R.Sethu Prabakaran, Government Counsel (Tax) ********** https://www.mhc.tn.gov.in/judis WP No. 23698 of 2026 __________ Page2 of 4 ORDER An order dated 05.01.2026 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 100% of the tax demand under the impugned order was recovered pursuant thereto. This aspect is required to be verified and confirmed. 5. Subject to verifying and confirming that 100% of the tax demand under the impugned order was recovered, the impugned order is set aside in order to provide an opportunity to the petitioner to contest the tax demand on merits. After providing a reasonable opportunity to the petitioner, a fresh order shall be issued within three months from the date of verifying and confirming the recovery. https://www.mhc.tn.gov.in/judis WP No. 23698 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. 02-07-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To Deputy State Tax Officer I Lakshminagar Assessment Circle, Tiruppur II First Floor, emperor building, no.16, indiranagar 1st street, avinashi road, tiruppur - 641603. https://www.mhc.tn.gov.in/judis WP No. 23698 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 23698 of 2026 and W.M.P.Nos.25665 & 25666 of 2026 02-07-2026 https://www.mhc.tn.gov.in/judis