WP No. 23891 of 2026 __________ Page1 of 4 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 03-07-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 23891 of 2026 and W.M.P.Nos.25939 & 25940 of 2026 Sri Venkateswara Steel Represented by its Partner D Selvarajan, No. 20, NA, Saravana Nagar, Kodungaiyur, Chennai, Tamil Nadu 600 118. ..Petitioner(s) Vs The Assistant Commissioner (ST)(FAC) Kodungaiyur Assessment circle Room No.103,IINd floor Integrated commercial Taxes building No.32, Elephant gate Bridge Road chennai-600 003 ..Respondent(s) PRAYER: Writ Petition filed under Article 226 of The Constitution of India praying for the issuance of a Writ of Certiorarified Mandamus, calling for the records of the impugned order issued by the Respondent in Proceedings No. GSTIN 33AAAFS7481D1ZC/ 2021-22 dated 12.12.2025 along with Order and Summary of Order in Form GST DRC 07 bearing Reference No. ZD331225189362F dated 12.12.2025, quash the same and consequently remand the matter to the Respondent directing them to entertain the records, documents https://www.mhc.tn.gov.in/judis WP No. 23891 of 2026 __________ Page2 of 4 and reply from the Petitioner and then pass order after affording a personal hearing to the Petitioner. For Petitioner(s): Ms.B.Abirami for Mr.M.Hariharan For Respondent(s): Ms.Amirta Poonkodi Dinakaran, Government Counsel (Tax) *********** ORDER An order dated 12.12.2025 is assailed on the ground that the petitioner did not have a reasonable opportunity to contest the tax demand on merits. 2. Ms.Amirta Poonkodi Dinakaran, 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. https://www.mhc.tn.gov.in/judis WP No. 23891 of 2026 __________ Page3 of 4 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, 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. 03-07-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To The Assistant Commissioner (ST)(FAC) Kodungaiyur Assessment circle Room No.103,IINd floor Integrated commercial Taxes building No.32, Elephant gate Bridge Road chennai-600 003 https://www.mhc.tn.gov.in/judis WP No. 23891 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 23891 of 2026 and W.M.P.Nos.25939 & 25940 of 2026 03-07-2026 https://www.mhc.tn.gov.in/judis