WP No. 23850 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. 23850 of 2026 and W.M.P.Nos.25894 & 25895 of 2026 M/s.SR JUNGLE RESORTS PRIVATE LIMITED Represented by its Director No.927, Kolikondai Anaikatti Main Road Anaikatti, Coimbatore-641 108. ..Petitioner(s) Vs The Assistant Commissioner (st) O/o.The Assistant Commissioner Vadavalli Assessment Circle Coimbatore- 641 018. ..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 entire records connected with the Impugned order of the Respondent and his Proceedings in Ref. No.ZD330226227074S in GSTIN / 33ABGCS1177C1ZN dated 25.02.2026 and quash the same. For Petitioner(s): Mr.A Arun For Respondent(s): Ms.Amirta Poonkodi Dinakaran, Government Counsel (Tax) *********** https://www.mhc.tn.gov.in/judis WP No. 23850 of 2026 __________ Page2 of 4 ORDER This is the second round of litigation relating to this assessment. The petitioner approached this Court challenging assessment order dated 17.04.2025 in W.P.No.48834 of 2025. Said writ petition was disposed of on 12.12.2025 directing the petitioner to deposit 25% of the disputed tax within thirty days from the date of receipt of a copy of the order. The petitioner was also directed to reply to the show cause notice. The petitioner remitted 25% on 08.01.2026. Because the petitioner did not reply, impugned order dated 25.02.2025 was issued. 2. Learned counsel for the petitioner submits that 100% of the tax demand under the impugned order was recovered. He seeks another opportunity. 3. Ms.Amirta Poonkodi Dinakaran, learned Government Counsel (Tax), accepts notice for the respondent. She submits that the impugned order was issued because the petitioner failed to comply with conditions imposed in the earlier order. 4. Given the fact that the impugned order was issued without hearing the petitioner and considering that 100% of the tax was recovered, the interest of https://www.mhc.tn.gov.in/judis WP No. 23850 of 2026 __________ Page3 of 4 justice warrants an opportunity being provided to the petitioner. Towards that end, the impugned order is set aside and the matter is remanded for re- consideration. The petitioner is granted fifteen days to reply to the show cause notice. Upon receipt thereof, the assessing officer is directed to provide a reasonable opportunity to the petitioner and issue a fresh order within three months from the date of receipt of the reply to the show cause notice. For the avoidance of doubt, it is clarified that amounts recovered earlier shall abide by the outcome of remanded proceedings. It is also clarified that this will be the final opportunity to the petitioner. 5. 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 The Assistant Commissioner (st) O/o.The Assistant Commissioner Vadavalli Assessment Circle Coimbatore- 641 018. https://www.mhc.tn.gov.in/judis WP No. 23850 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 23850 of 2026 and W.M.P.Nos.25894 & 25895 of 2026 03-07-2026 https://www.mhc.tn.gov.in/judis