WP No. 24177 of 2026 __________ Page1 of 4 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 06-07-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 24177 of 2026 and W.M.P.Nos.26297 & 26299 of 2026 Tvl. Sathya Agencies Represented by its Proprietor, Mr. Sathiya Gandhi No. 6/13, Seetha Ram Nagar, 2nd Street, Kodungaiyur, Chennai, Tamil Nadu 600 118. ..Petitioner(s) Vs The State Tax Officer Ayanavaram Assessment Circle, No.1 Greams Road, 3rd Floor, PAPJM Annex Building, Chennai-600 006 ..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. ZD331225404423X dated 26.12.2025 along with the detailed order in GSTIN 33GIVPS6049Q1ZY/ 2021-22 dated 26.12.2025 for the tax period APR 2021 MAR 2022 and quash the same. For Petitioner(s): Mr.B. Syed Abdul Wakeel https://www.mhc.tn.gov.in/judis WP No. 24177 of 2026 __________ Page2 of 4 For Respondent(s): Ms.G.Dhana Madhri, 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. 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, https://www.mhc.tn.gov.in/judis WP No. 24177 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. 06-07-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To The State Tax Officer Ayanavaram Assessment Circle, No.1 Greams Road, 3rd Floo, PAPJM Annex Building, Chennai-600 006 https://www.mhc.tn.gov.in/judis WP No. 24177 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 24177 of 2026 and W.M.P.Nos.26297 & 26299 of 2026 06-07-2026 https://www.mhc.tn.gov.in/judis