WP No. 24344 of 2026 __________ Page1 of 4 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 07-07-2026 CORAM THE HON'BLE MR JUSTICE SENTHILKUMAR RAMAMOORTHY WP No. 24344 of 2026 and W.M.P.Nos.26524 & 26525 of 2026 Tvl.S MART GSTIN. 33AQSPN2291C1ZT, Represented by its Proprietor Mr. Naresh Kumar, Old Door No 60, New Door 160/1, Rathinagiri Road, Saravanampatti, Vilankurichi East, Karattumedu, Coimbatore 641 035. ..Petitioner(s) Vs The Deputy State Tax officer-2 Saravanampatti East Circle, Commercial Tax Building, Dr. Balasundaram Road, 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, call for the records pertaining to impugned Order in Form GST DRC 07 bearing reference no. ZD3304251239595/2022-23 dated 16.04.2025 issued by the Respondent and quash the same being illegal, invalid without jurisdiction. For Petitioner(s): Mr.G.V.Monika Sri https://www.mhc.tn.gov.in/judis WP No. 24344 of 2026 __________ Page2 of 4 For Respondent(s): Mr.R.Sethu Prabakaran, Government Counsel (Tax) ********** ORDER An order dated 16.04.2025 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. 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. 24344 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. 07-07-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No RNA To The Deputy State Tax officer-2 Saravanampatti East Circle, Commecial Tax Building, Dr. Balasundaram Road, Coimbatore- 641 018. https://www.mhc.tn.gov.in/judis WP No. 24344 of 2026 __________ Page4 of 4 SENTHILKUMAR RAMAMOORTHY, J. RNA WP No. 24344 of 2026 and W.M.P.Nos.26524 & 26525 of 2026 07-07-2026 https://www.mhc.tn.gov.in/judis