WP No. 23842 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. 23842 of 2026 and W.M.P.Nos.25881, 25884 & 25886 of 2026 Mr Palani Murugan Proprietor, Murugan Ceramic Mart, NO.203/1A, VETRI VELAMPURI VINAYAGAR NAGAR, GANDHI STREET, VILANKURICHI, CHERANMANAGAR, COIMBATORE-641035 ..Petitioner(s) Vs 1. Assistant Commissioner (st) (fac) Saravanapatti East circle Coimbatore-18 2. Deputy Commissioner CT Coimbatore ..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 relating to the impugned order bearing Form GST APL-02 Reference Number ZD330426069748X dated 08/04/2026, passed by the Second Respondent, quash the same and direct the Second Respondent to adjudicate the appeal covered in the impugned order on grounds raised in the appeal after granting opportunity of personal hearing to the Petitioner, https://www.mhc.tn.gov.in/judis WP No. 23842 of 2026 __________ Page2 of 4 For Petitioner(s): Ms.Yazhini Sampathkumar For Respondent(s): Ms.Amirta Poonkodi Dinakaran, Government Counsel (Tax) ************ ORDER An assessment order was issued on 26.11.2025. Such order was challenged by lodging an appeal on 27.03.2026. Said appeal was dismissed solely on the ground of limitation. 2. Ms.Amirta Poonkodi Dinakaran, learned Government Counsel (Tax), accepts notice for both the respondents. 3. Learned counsel for the petitioner submits that the time limit for filing the appeal and the condonable period is required to be computed after excluding the date of the order. If so computed, she submits that the appeal was lodged within the condonable period. 4. The delay, if any, is by one day. Section 12 of the Limitation Act, 1963 provides for the exclusion of the date of issuance of the order while computing the period of limitation. While the Limitation Act, 1963 does not per se apply to proceedings before a quasi-judicial authority, the principles https://www.mhc.tn.gov.in/judis WP No. 23842 of 2026 __________ Page3 of 4 underlying the Limitation Act may arguably apply. Considering this aspect, in exercise of equitable jurisdiction, I find that the appeal of the petitioner is liable to be received and considered subject to the filing of an application to condone delay. 5. Towards this end, the impugned appellate order is set aside and the appellate authority is directed to receive the appeal, if lodged with an application to condone delay, within fifteen days from the date of receipt of a copy of this order. 6. This writ petition is disposed of on the above terms. There shall be no order as to costs. Consequently, the connected writ miscellaneous petitions are closed. 03-07-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To 1. Assistant Commissioner (st) (fac) Saravanapatti East circle, Coimbatore-18 2. Deputy Commissioner CT Coimbatore https://www.mhc.tn.gov.in/judis WP No. 23842 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 23842 of 2026 and W.M.P.Nos.25881, 25884 & 25886 of 2026 03-07-2026 https://www.mhc.tn.gov.in/judis